Corrective Action Plans

Finding 2022-004 ? Special Education Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Michael Huber Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When our current contract is nearing its end we will follow procurement bid procedures. Anticipated Completion Date: 2029

Proposed Completion Date: June 30, 2023

Finding 2022-002 Federal Agency Name: Department of Treasury, State of South Dakota Governor?s Office of Economic Development Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Finding Summary: The Company has not documented their internal controls for compliance with the procurement, suspension and debarment compliance requirement of Uniform Guidance as outlined above. The Company does not have a written policy related to procurement or written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurement, as well as, established procedures in place related to suspension and debarment. The Company did not follow the procurement method required based on the dollar amount and conditions specified in 2 CFR 200.320. For contracted vendors with expenditures in excess of $25,000, the Company did not verify vendors were not suspended or debarred prior to entering into transaction with the vendor. Responsible Individuals: James Groft, CEO Corrective Action Plan: The Company will draft and adopt policies that implement internal controls consistent with the compliance requirements for procurement, suspension and debarment. The Company will follow the new documented policies and retain documentation to support compliance with the requirements. Anticipated Completion Date: June 1st, 2023

Contact Person Responsible for Corrective Action: Sean Begley Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding partially. All purchases from C&T Design were for different types of kitchen equipment located in different schools throughout the school district. For the time period audited, there were eight purchase orders. Of these purchase orders, three were created prior to the hiring of the new Director of Operations in July 2021. For the five purchase orders created by the Director of Operations, the five POs are for different types of equipment in two different schools and should be considered different projects. For each purchase a minimum of three different qualified vendors were provided the same scope, the same time, and deadline for providing a quote. In each case, C&T Design was the lowest. At the same time, the IDOE Division of School and Community Nutrition Program is expecting the School Town of Munster to follow a spend down plan in order to comply with maintaining an appropriate cash balance in the food service account. As specified in Finding 2022-005, barring a vendor from bidding due to the aggregate amount of goods and/or services provided to multiple School Town of Munster schools in one year would disqualify a company that consistently provided the lowest bid. Description of Corrective Action Plan: The School Town of Munster will have the school attorney conduct a legal review for all projects with an estimated cost over $50,000 to ensure compliance under Indiana Code 4-13.6-5 Chapter 5 ? Bidding Requirements. We will use SAM.GOV to verify that vendors we use are neither suspended nor debarred. Anticipated Completion Date: August 2023

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all vendors are reviewed against the debarred vendors listing prior to entering the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization currently utilizes a third-party vendor, Compliatric, to screen vendors in accordance with SAM.gov requirements on a routine basis. However, a procedure does not currently exist to ensure 100% of new vendors are entered into this separate system. A procedure is being developed to ensure that all new vendors are entered into Compliatric, and screening is completed prior to entering into a contract. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all disbursements charged to the federal follow the proper procurement standards and to maintain support for the procurement methods used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 (Continued) Action taken in response to finding: The Organization is reviewing and modifying the Purchase Requisition and Purchase Order Policy to reflect current practices more accurately, update federal regulations and associated purchase thresholds. In addition, the Organization is improving internal procedures to manage requisition submittals which reach thresholds that would dictate multiple bid submittals as well as ensure an annual training of the Organization?s management and purchasers on policy parameters. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

Finding 2022-002 ? Procurement, Suspension, and Debarment Contact Person: Michael R. Castilleja, Director of Procurement & Other Support Services Current Status: Correction of this finding is in-progress. Anticipated Completion Date: December 31, 2023 Condition: The University did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, as required by the University?s Procurement and Bid Policy, the University did not maintain and provide documentation of the performance of an annual pricing review in order to assess whether preferred vendors continue to provide comparable pricing to other vendors. Identification of repeat finding: N/A UIW is committed to complying with the Procurement, Suspension, and Debarment regulations as indicated in the Uniform Guidance Procurement Standards (2 CFR ? 200.317 through 200.327). The University?s practice to maintain records for procurements which include the rationale for the method of procurement, selection of contract type, price analysis (including bidding process) and justification of vendor selection are currently being followed. Due to the urgency and state of emergency the University was under, it hindered our efforts of documenting our procurement practices. An oversight of the Procurement Standards has been reviewed and we are confident that our policies and procedures are sufficient to satisfy the requirements of the regulations. In addition, the University will implement a Sole Source/Preferred Vendor Form that will require justification and evidence of a vendor meeting the requirements of the purchase within a reasonable, allowable and consistent manner. ? Sole Source Vendors will be identified by department needs and may be requested at time of purchase requisition. Determination will be based on vendor availability of products and needs. ? Preferred Vendors will be maintained for the year and must be requested for market pricing review to include date of request, vendor category and price for like items. The Preferred Vendors list will be maintained in the Procurement Department and may be requested for review by initiator of purchase requisitions. All Sole Source/Preferred Vendor request should be reviewed/signed by requestor, a Procurement Officer, and the CFO & VP for Finance and Administration.

Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) CFDA No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Repeat Finding from Prior Year: Yes, prior year finding 2021-09. Management?s or Department?s Response: We Concur. Views of Responsible Officials and Corrective Action: Procedures have been developed and implemented to comply with the County?s policies over procurement and suspension and debarment. Name of Responsible Person: Bruce Cosby Name of Department Contact: Bruce Cosby Projected Implementation Date: July 1, 2023

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

Finding 2022-003 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: Frontier School Corporation will have the Food Service Director prepare contacts to all possible food & drink vendors asking for Vendor Bids for the following school year. Any email correspondence will be CC?d to the Corporation Treasurer and Superintendent when contacting the Vendors. A phone call log will also be kept by the Food Service Director. After receiving Vendor Bids, all Vendor Bids or Vendor Declining to Bid will be presented to the School Board for their approval. The Food Service Director will also give a recommendation at that time on who they would like to award the Vendor Bid to. After the School Board vote on Vendor Bid Awards, e-mail correspondence will be sent to all vendors with Corporation Secretary and Superintendent CC?d. All email data, phone logs, and School Board notes will be filed in the Food Service Director?s office. This internal control system will ensure compliance with the state Procurement agreements and requirements. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. Suspension and Debarment: Frontier School Corporation Food Service Director will check SAM Exclusions, collect a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. This information would then be kept in the Vendor?s file. Anticipated Completion Date: The CAP will be in place by March 17, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. The Food Service Director will have current vendors checked on SAM Exclusion or have a certification from that vendor, or adding a clause or condition to the covered transactions with the current vendors by March, 17, 2023.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number: (812) 438-2655 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will maintain communication with the Wilson Education Center to ensure that they comply with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. In the event that the Wilson Education Center does not comply with the above requirement, the school corporation will look at the federal website to ensure that all vendors are on the approved list. If the Wilson Education Center fails to meet the above criteria, the school corporation would advertise to solicit bids for milk and bread. Anticipated Completion Date: January 13, 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Judy Brooks, Food Service Coordinator Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Coordinator will follow our procurement procedures for all purchases. Food Service Coordinator will document that vendors for the BID are not suspended or debarred from participation in federal programs before purchasing also vendors used through the Wilson Center. The Deputy Treasurer will verify procurement and suspension and debarment documentation is on file before payment is made. When we are checking the vendors on the sams.gov website and there are no results founds then we will also request the vendor to submit a suspended and debarred form. Anticipated Completion Date: 2/13/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. It is the responsibility of the Food Service Director to ensure compliance and comply with the grant agreement and the Procurement and Debarment compliance requirements. Each School year, the Food Service Director & Superintendent will present the West Central IN ESC Food Service Bids & any Food Service Small Purchase quotes to the School Board for review and approval. Audit Evidence will be the Board packets and Board Minutes. Food Service Small Purchases- The Food Service Director will obtain quotes directly from the vendors or use the vendor?s website/catalog to compare products and prices. The Food Service Director attends WCIESC procurement meetings to get the most up-to-date pricing information. It is the responsibility of the Food Service Director to keep all documentation. The Food Service Director will present the documentation to the Business Manager for review. Small Purchase Vendors will be approved by the School board each School Year. Audit Evidence will be the quote documentation as well as the Board packets and Board Minutes. Anticipated Completion Date: March 15, 2023

FINDING 2022-006 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. The Special Education Director will obtain pricing when cumulative costs are projected to exceed the micro purchase threshold an adequate number of qualified sources. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Anticipated Completion Date: July 31, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Thomas Gordon, Beverly Hindes Contact Phone Number: 219-996-4771 x107 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director and Superintendent will collect sealed bids or competitive proposals, as required. Furthermore, vendors will be verified with SAM for any disqualifications from participating in federal assistance programs. Anticipated Completion Date: January 2023

FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Procurement, Suspension and Debarment Auditor Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Management/Responsible Officials and Corrective Action: The City concurs with the auditor?s recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit before and was not aware that the procurement standards identified in Title 2 of the Code of Federal Regulations (CFR), specifically 2 CFR sections 200.317 through 200.326, had to be included in the City?s procurement policy. Being that this was the first time the City received the ARPA funding and was subject to this requirement, this deficiency came up. The City will review and bring its current policy up to date. The City also made an effort to comply when a deficiency was known. In August 2022, the City established its Debarment and Suspension policy. With this policy in place, the City will review its current process to ensure that going forward, verifications for debarment and suspension are performed for contractors prior to entering into transactions with them. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jennifer Farley Contact Phone Number: 765-292-2626 View of Responsible Official: I concur with the finding. COVID -19 Procurement and suspension and debarment: 1. I was unaware of these requirements at the time the money was spent. In the future I will make sure this is done correctly. Anticipated Completion Date: Done

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Amanda Bilbrey, Food Service Assistant Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Food Service will review bid packets to ensure documentation was provided as proof that the vendors were not suspended or debarred. If such evidence is not provided, the Food Service Director will verify and request appropriate documentation. Anticipated Completion Date: March 24, 2023

Finding Number: 2022-002 Planned Corrective Action: See Below Anticipated Completion Date: 01/05/2023 Responsible Contact Person: Brian Haines, Treasurer 1. The Treasurer will educate all responsible parties (Director of Curriculum, Assistant Superintendent, Accounts Payable, Superintendent) in the District regarding to Federal Procurement requirements. 2. The Treasurer will ensure that all requests follow the Districts Purchasing Procedures, as well as the Federal Procurement Requirements.

FINDING:2022-003 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: In the future the Food Service Director will check on Sam.gov for any Disbarment on any purchases that is over $10,000.00. She will print it out and initial and keep on file. In the future the Food Service Director will include in their Service Agreement form #1048, for Disbarment, Suspension. The School Corporation will seek Bids/Quotes for anything over $10,00.00 in the future. If the school is not asking for Bids/Quotes for repairs, we will use the company that we have a Maintenance Agreement with. Anticipated Completion Date: February 2023

Condition: Three vendors were awarded a contract without a proper competitive procurement process. Corrective Action Planned: The City and School Department has implemented procedures to perform procurement procedures on all applicable contracts for goods and services that will be in compliance with both Federal and State procurement laws. We feel the finding has been resolved going forward. Anticipated Completion Date: 2023-2024 school year Contact: Kenny Costa, City Auditor and Gary Frisch, School Chief Financial Officer

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will anticipate annual procurement expenses with vendors outside of the Southern Indiana Education Center, If the anticipated expenses for the fiscal year are in excess of $10,000 but less than $150,000, the food service director will work to obtain quotes from at least three sources. If the anticipated expenses for the time period are in excess of $150,000, the food service director will conduct a formal bid process and award a contract to the most qualified, lowestpriced vendor. Any vendor with a contract for purchases of $25,000 or more will need to provide a certification or include a contract clause stating the vendor is not suspended or disbarred from participation in federal assistance programs. If not certification or contract clause is produced, the food service director will contact the corporation treasurer to check the vendor's status in SAM. Anticipated Completion Date: August, 2023

CORRECTIVE ACTION PLAN FINDING 2022-004 Contact Person Responsible for Corrective Action: Region 8/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

District Response: A. What corrective action will be taken: District will follow all the requirements of 2 CFR 200 with respect to federal procurement requirements. B. Who is responsible (name and position): Dr. Stephen Gregory, Federal Program Director C. When will the plan be implemented? Corrective action started May 5, 2023, and will continue.

The Fiscal Officer and management company have reviewed the description of the issues and are taking steps to put stronger documentation procedures in place that will support the evaluation and selection of vendors paid from Federal programs. With respect to these specific purchases in FY22, we are confident that if the process had been appropriately documented, we would have reached similar conclusions about who was ultimately selected as the vendor for these projects. We believe the corrective actions we are taking will put us in full compliance with 2 CFR part 200 and the School?s Federal Procurement Policy in future periods.