Corrective Action Plans

The County will establish policies and procedures to create better communication between the Emergency Manager and the County Officers.

2021-005 Procurement Standards set out at 2 CFR sections 200.318 through 200.326 Management Response: The Tribe will update fiscal, payroll, HR, and procurement policies by the end of the year. Anticipated Completion Date: 12/31/2024 Responsible Party: Treasurer, Comptroller, Accounting Manager and Federal Programs Accounting Manager

2021-003 Summary of Finding (optional) Missing Documentation for procurement, suspension and debarment: Per Uniform Guidance 2 CFR 200.318, any contracts procured with federal funds for over $10,000 should be obtained via a bidding process or documentation is required to show that the contractor is the sole source for the services. In addition, the Organization should keep documentation to show that they have verified that contractors are not suspended or debarred. Bid or sole source documentation was missing for one contract and in addition, for that contract, there was no documentation of the verification that the contractor was not suspended or debarred. We consider this to be an instance of non-compliance and a significant deficiency in internal control over compliance for the reporting requirement. Statement of Concurrence or Nonconcurrence The Maryland Network Against Domestic Violence concurs with this finding. Corrective Action The contract highlighted as part of this audit was a contract that predated FY21 and both the current Executive Director and Finance Manager. As this was not a new contract, no bid or verification that the contractor was not suspended or debarred was conducted during FY21. g However, it is understood that this should have been completed in prior years and the fact that there was no documentation to support the completion of this activity is problematic. In order to ensure that proper sole source documentation is in place, MNADV will review all sole source contracts over $10,000 and verify that a bid process is in place and all vendors are properly vetted for suspension or debarment. This will be completed by May 31, 2024.

2021-006 - Compliance with Uniform Guidance - Procurement; During the 23-24 fiscal year, the Controller (Jarri Melton) audited the vendors more than the $25,000 threshold to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. The Agency developed and implemented a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. During the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency followed 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed by the Controller (Jarri Melton), then filed. The Payables Accountant (TBD) and the Controller (Jarri Melton) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. here are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (TBD). The Revenue Accountant (Deena Iaccarino) and Purchasing Clerk (Marissa Anderson) assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (TBD) to retrieve when closing out the month. The Controller (Jarri Melton) will ensure this occurs by conducting monthly reviews. The CEO (Marianne Gribbon) will monitor the process, quarterly.

Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the serious nature of this finding and the compliance required with 2 CFR sections 200.318 through 200.327, as well as Part 1326 for vendor exclusions. The Interim Controller and Director of Finance will be revising procedures to document requirements for all procurement activities, regardless of type. Staff will attend training to ensure all procurement activities adhere to the CFR requirements and company policies. Periodic reviews of the procurement activities will be performed to ensure compliance with these procedures to mitigate the risk of continued deficiencies. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: March 2024

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization familiarize itself with the procurement regulations prior to entering into any future federal grants and review state and federal guidance. Explanation of disagreement with audit finding The Child and Adult Care Food Program was created as an emergency response during the COVID-19 pandemic. In such an emergent situation, management believes the federal government acted in good faith to meet the needs of the country by contracting with regional sponsoring organizations. New Vision Foundation was selected by the sponsoring organization to be a community-based food provider to culturally-specific populations. All activities related to the program were expressly approved by the sponsoring organization. The finding of material noncompliance is overstated. Management followed all guidelines and fulfilled all obligations outlined by Feeding Our Future. Procurement procedures and contracting processes used by management were approved by the sponsor organization. Action taken in response to finding The program noted was discontinued at the end of 2021. If the Organization enters into any other federal funding, we will consult with experts on compliance requirements from the start of the grant. Name of the contact person responsible for corrective action Hussein Farah, Executive Director Planned completion date for corrective action plan N/A

Management of the Organization has stated the process of creating new and updating policies, procedures related to financial reporting, activities, including written procurement standards and written conflicts of interest.

Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.

Management Response to Audit Comment # 2021-005 INTERNAL CONTROLS OVER DISBURSEMENTS OF FEDERAL FUNDS MUST BE IMPROVED HEAD START AND EARLY HEAD START PROGRAMS Federal Assistance listing # 93.600 Responsible Person: G. Keith Williams/ CCCSA Management Anticipated Completion Date: December 31, 2023 Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and takes exception to several of the items listed. For example, some of the transactions listed that were missing check requests (both Head Start/Early Head Start and Indirect Cost Pool) were for monthly expenditures like utility bills, insurance, rent and other contractual obligations. Management has not in the past issued a check request each month for these transactions as they are a part of the ongoing operation of the programs listed. Transactions listed with only one signature occurred as an oversight as the banking authority only requires one signature while our policy may indicate two signatures. Management feels the purchase of the truck was procured in agreement with approvals from the funding agency and board as required. Proper documentation was provided and is currently available for further review. Management continues to follow the proper guidelines regarding procurement and purchases related to the policies and procedures of the agency as well as micro purchase guidelines set forth by the Federal awarding agency. The Board of Directors also approved a revision to the policies and procedures requiring two “live” signatures on all checks issued by the agency. There is also an ongoing review of the current policies and procedures and recommendations for changes and updates are forthcoming. Management reserves the right for further review of these findings with the audit firm for additional documentation and resolution.

FINDING 2021-003 Contact Person Responsible for Corrective Action: Porter County Auditor Contact Phone Number: 219-465-3445 Views of Responsible Official: County concurs with audit finding Description of Corrective Action Plan: County will keep records of all procurement items for Federally-funded projects in accordance with 2 CFR 200.318(i) requirements in project files as they are approved by the relevant department. Anticipated Completion Date: 12/1/2023

Title 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters), Responsible personnel will attend training classes by OSAI, OEM, and Muskogee Creek Nation to stay updated on allowable expenditures and record keeping techniques to allow for more accurate reporting. I will work with the County Emergency Management Coordinator to ensure quarterly reports are filed on time., Responsible Contact Person Board of County Commission Chairman - James Yandell

The County will make sure that all federal documentation is maintained by each district for inspection and will ensure it is accurately reported on the SEFA.

I am aware of the audit findings involving FEMA Disaster 4315. I apologize for the delayed response letter. On behalf of Dewey County District 2, we want to assure you we are here to help and assist in anything you or your office may need from myself, or from any District 2 employee.

Finding ref number: 2020-002 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 at the time of this audit. Anticipated date to complete the corrective action: No later than 12/31/24

Finding No.: 2019-016 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.870 Maternal, Infant and Early Childhood Home Visiting Grant Program Award Number: 1X10MC31162-01-00 Area: Procurement and Suspension and Debarment Questioned Costs: $60,104 Contact Persons: Perlie Santos, Chief Financial Officer; Yuline Cruz, MIECHV Program Manager; Vincent Camacho, Grants Administrator; Cora Ada, Procurement Director. Corrective Action: CHCC concurs with the findings but not the questioned costs. Although not timely scanned and sent electronically to the Auditors, the Procurement Documents are available for testing. In fiscal year 2020, CHCC implemented the document routing repository for the procurement process using Laserfiche Forms. This will enable CHCC to warehouse all supporting documentation related to procurement activities and document the approval process. With the implementation of the Munis Financial Information System in January 2023, CHCC is now able to electronically attach scanned supporting documents to the vouchers through the Tyler Content Manager (TCM). This will allow for audit testing to be done by providing auditors view only access to CHCC Financial Information System. Proposed Completion Date: On-Going

Finding No.: 2019-011 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 and 5H795M062879-02 Area: Procurement and Suspension and Debarment Questioned Costs: $183,926 Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator; Cora Ada, Procurement Director; Chellah Sablan, Comptroller. Corrective Action: CHCC concurs with the findings but not the questioned costs. Although not timely scanned and sent electronically to the Auditors, the Procurement Documents are available for testing. In Fiscal Year 2020, CHCC implemented the document routing repository for the procurement process using Laserfiche Forms. This will enable CHCC to warehouse all supporting documentation related to procurement activities and document the approval process. With the implementation of the Munis Financial Information System in January 2023, CHCC is now able to electronically attach scanned supporting documents to the vouchers through the Tyler Content Manager (TCM). This will allow for audit testing to be done by providing auditors view only access to CHCC Financial Information System. Proposed Completion Date: On-Going

Finding No.: 2019-007 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Award Number: 5U79SM062447-04 Area: Procurement and Suspension and Debarment Questioned Costs: $23,500 Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator; Cora Ada, Procurement Director. Corrective Action: Condition 1 CHCC does not concur with the findings and the questioned costs. RFP19-CHCC/CHC-SOC-019 was published for Contract 686641, that supports Document 1475823 for $9,800. Document 1430779 was encumbered using 672067OM. This is a bridge obligation through an approved request for payment memorandum, while the contract was in progress. ITB 16-CHCC/CGC-002 was published for Contract 621100, that supports documents 1456419 for $850 and 1440996 for $850. Condition 2 and 3 CHCC does not concur with the findings and the questioned costs. The requested documentation was provided, however, CHCC acknowledges that the file sent referenced the Purchase Order numbers and the Document number (Payment Voucher Number). This may have resulted in auditors not properly associating the provided Purchase Orders to the selected payment vouchers. 2019-007 Finding No.: 2019-007, Continued With the implementation of the Munis Financial Information System in January 2023, CHCC is now able to electronically attach Purchase Orders to the Invoices and supporting documents are also electronically linked to the Purchase Order and invoices. This will allow for audit testing to be done by providing auditors view only access to CHCC Financial Information System. Condition 4 CHCC does not concur with the findings and the questioned costs. Although solicitations were not obtained for the car rental for the 4th year of the grant, CHCC believes that the vehicle rental agreement was competitively procured during the initial years of the rental. The agreement was rolled over annually to avoid disruption of service and program activity. To illustrate that, although no solicitation was obtained on the subsequent rental renewal, CHCC still ensures reasonableness of cost. For this agreement, the rental was even reduced from $950 per month to $900 per month on the 5th year of the agreement. Proposed Completion Date: Not applicable as CHCC does not concur with the findings.

We are creating a position and job description for a project manager who will work closely with the Controller and Executive Director. The project manager will be responsible for creating the bid packages, the contractor selection, managing the construction project, and documenting finaI resuIts of the project. The anticipated completion date for this corrective action is July 31, 2024.

Action Plan to Address Policy Updates and Implementation (Finding 2018-001): a. Review and Update Policies: Begin by conducting a comprehensive review of existing policies, particularly those related to procurement, suspension, and debarment. Ensure these policies align with the latest HRSA requirements and federal regulations. b. Engage a Policy Consultant: Seek the expertise of a policy consultant or legal counsel well-versed in healthcare compliance and HRSA regulations to assist in policy revision. c. Policy Training: Develop a training program to educate staff, especially key personnel like the CEO and CFO, on the updated policies. This training should emphasize the significance of compliance and the potential consequences of non-compliance. d. Implementation Oversight: Appoint a Compliance Officer responsible for overseeing the implementation of updated policies and procedures. This officer should regularly audit and monitor adherence to these policies. e. Documentation and Reporting: Implement a robust documentation system to track policy adherence and any deviations. Ensure that timely and accurate reports are generated for review by internal committees and the board. f. Board and Committee Involvement: Enhance board and committee involvement in the oversight of policy compliance. Provide regular updates and reports to these entities to keep them informed and engaged in the compliance process. g. Continuous Monitoring: Establish a continuous monitoring process to identify any policy-related deficiencies promptly. Regularly assess the effectiveness of policies and make necessary adjustments. h. External Audit: Schedule an external audit ahead of time by an independent auditor or agency to ensure objectivity and compliance with HRSA standards. i. Communication: Promote a culture of compliance through effective communication channels. Encourage employees at all levels to report potential violations or concerns without fear of retaliation. j. Periodic Review: Commit to a periodic review of policies, at least annually, to ensure they remain current and aligned with any evolving HRSA regulations or federal mandates.