Corrective Action Plans

FINDING 2022-002 Contact Person Responsible for Corrective Action: Bryce Welsh Contact Phone Number:765-345-5101 Views of Responsible Official: We concur with the finding. While we believe that we had controls in place for this finding we failed to produce the proper documentation to prove that we did so. Description of Corrective Action Plan: Going forward we will make sure that all suspension and debarment documents are provided to the Business Manager and kept at central office. These documents will be reviewed and signed by the Business Manger showing internal controls are in place. We will also ensure that we have a contract with the vendors for purchases between $50,000 and $100,000. Anticipated Completion Date: 3/14/2023

Finding Number: 2022-002 Condition: Of the 18 procurement samples tested for the Research & Development cluster, 10 samples did not support full and open competition. Planned Corrective Action: Management does follow appropriate process but did not document same. Management will revise its Procurement Policy and incorporate auditor?s suggestion for single source documentation. Contact person responsible for corrective action: Luba Kagan Anticipated Completion Date: October 31, 2022

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jami Parks Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The School Corporation will sign agreements with Food2School for all Food Service contracts to obtain quotes, these quotes will meet Procurement, Micro purchases and simplified acquisition requirements. Food2Schools will also obtain and share documentation with the school showing vendors meet suspension and disbarment requirements. Anticipated Completion Date: August 01, 2023 (Beginning of the 23/24 school years)

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Jake Roger, Town Administrator. Corrective Action Plan: The Town will produce policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Completion Date: December 31, 2023.

FINDING: 2022-002 Contact Person Responsible for Corrective Action: Deborah A. Longer, Clerk-Treasurer Contact Phone Number: (219) 942-1940 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The special purchase procurement of the CNG refuse haulers was done by Resolution of the Board of Public Works and Safety. This Resolution included references to the State Statutes permitting acquisitions of this type but did not include any reference to the Federal statutes and requirements. In addition, the Employee in Responsible Charge (ERC) and the agency assisting with the grants and purchasing failed to verify that the vendor was neither suspended nor debarred to assure they would be a qualified vendor. The City Attorney has been appraised of both of these issues. In the future, any special purchase of equipment that utilizes Federal funding will include a reference to the State and Federal statutes governing such in the City?s official action prior to moving forward and will meet all of the requirements of same. In addition, the City Attorney has included in all City contracts that the Vendor is required to provide assurances that they are a qualified vendor and not currently suspended or disbarred from doing business. In addition, each ERC will be provided a copy of the Finding 2022-02 to serve as a reminder of their responsibilities and the necessary procedures and activities related to the overseeing of the grants and direct them to review the Internal Control Policies regarding the responsibilities, procedures and activities to assure the proper reporting in all areas of the SEFA in future years. Anticipated Completion Date: April 30, 2023 Signed: Deborah A. Longer Deborah A. Longer, Clerk-Treasurer Date: April 19, 2023

U.S. Department of Housing and Urban Development Lake Wales Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-001 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority update it Procurement Policy from 2009, which was done on September 30, 2022, putting in place the procurements listed in the Uniform Guidance (UG) and clarifying procurement methods. As well as, including in the policy that all vendors? eligibility needs to be verified prior to signing contracts, either through the SAM website or by collecting a certification form from the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The new procurement policy was approved September 20, 2022 Name of the contact person responsible for corrective action: Al Kirkland, Executive Director Planned completion date for corrective action plan: Completed September 20, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Al Kirkland, Executive Director at (863)676-7414 ext. 12.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Contact Person Responsible for Corrective Action: Natalie McGinnis, School Lunch Treasurer and Joe Sheffer, School Lunch Coordinator Contact Phone Number: 812-358-4271 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: Simplified Acquisition - The Lunch Fund Treasurer and the Food Services Director will solicit bids for purchases that exceed the simplified acquisition threshold of $150,000 and in the event that two bids are not received, we will obtain documentation and will present bids and documentation to the Board of School Trustees for their approval. Small Purchases - The Lunch Fund Treasurer and the Food Services Director will solicit quotes for purchases that fall within the small purchase threshold of $10,000 to $150,000 and in the event that two quotes are not received, we will obtain documentation and will present quotes and documentation for review by other employee with knowledge of the compliance requirement will sign as proof of review. Suspension and Debarment: For transactions considered covered transactions (purchases to vendors exceeding $25,000), the Lunch Fund Treasurer will conduct a SAM search to ensure that the vendor is not suspended or debarred and is eligible to participate in federally funded programs. Should the vendor be suspended or debarred, a contract will not be awarded. A copy will be kept in the Food Service Department. The Lunch Fund Treasurer and Food Service Coordinator or other employee with knowledge of the compliance requirement will sign as proof of review. Anticipated Completion Date: Immediate

FINDING 2022-004 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Micro-Purchases The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist will enter claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. Small Purchases For Small Purchases, the School Corporation will obtain 3 quotes. Documentation of the 3 quotes are kept within the financial software system or electronically. For purchases about $50,000, GCS will enter into a contract with the vendor, after verifying that the vendor is not suspended or disbarred on SAM.gov. The contract will be electronically maintained by the Purchasing Specialist and uploaded to Gateway. Exceeds Simplified Acquisitions Signed and approved contracts will be maintained and filed electronically by the Purchasing Specialist. Suspension and Debarment All contracts will include documentation from SAM.gov that the vendor has not been suspended or disbarred. Anticipated Completion Date: April 2023

The City of Thibodaux was unaware of the federal mandate for procuring engineering services. One project was a supplement to a project that had a portion left off of the initial project. Since the City of Thibodaux already had an engineer in place, a contract amendment with the engineer was executed. However, this construction project totals over $1.1 million without engineering services; therefore, the City feel it can still substantiate the costs with the use of Coronavirus funding. The City had already decided and executed a contract with a local engineer for the second project before deciding to use Coronavirus funding for the project. However, this construction project totals over $3.7 million without engineering services; therefore, the City feels it can still substantiate the cost with the use of Coronavirus funding. The Finance Director, Jessica Hebert, will work on updating the policy by December 31, 2023.

December 14, 2022 Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 Finding 2022-001 U.S. Department of Education 84.370C- DC Opportunity Scholarship Program Significant Deficiency over Compliance and Internal Control over Procurement and Suspension and Debarment Planned Corrective Action: In response to last year's finding the School did implement more stringent procurement processes which include requiring the completion of a Grants Compliance Checklist prior to any spending on a federal grant. This was completed in the case of this vendor and demonstrated evidence of utilizing the simplified acquisition threshold (SAT) process was provided. However, we underestimated the amount we would spend on the the vendor. In our weekly accounting meeting, the School has implemented a process to monitor its vendors that have exceeded $20,000, to ensure year to data costs do not exceed $25,000. Beginning in September 2021, the School provided individual training to all budget managers which highlights federal and local procurement processes. We have also implemented quarterly meetings with all budget managers to ensure we are aware of upcoming expenses that may exceed the $25K threshold and/or incremental expenses that may exceed $25K with one vendor. Finally, we are proactively bidding out all contracts that exceeded $25K last year. Name of Contact Person: Tiffany Godbout, COO, 202-269-6623, tiffany@aohdc.org Anticipated completion date: The Corrective Action Plan will be implemented no later than January 1, 2023.

Description of Finding: During the Auditor?s control and compliance test work the following was noted: o In testing three of the consultants used, all three had contracts that exceeded $25,000 but were not tested for suspension and debarment. o In testing three of the consultants, used, all three had contracts that exceed the Simplified Acquisition Threshold (SAT) of $250,000, but no sealed bids, proposals, or documentation of sole source was performed. o Through further inquiry, the written ?micropurchase? policy of $50,000 was not self-certified. o Through further inquiry, small purchases that exceed micropurchase policy but are less than SAT did not obtain quotations. As a result, FHI is not in compliance with federal requirements when entering into procurement contracts as well as not meeting suspension and debarment requirements by potentially contracting with a suspended or debarred vendor. Statement of Concurrence or Nonconcurrence: A resume of every contractor and their budgeted compensation was provided to the Department of Agriculture with our competitive application as well as with the service agreement contract signed by both representatives of USDA and FHI. Because of timing on the grantor?s end, FHI has less than 10 business days to review and ratify contract and no one at USDA questioned use of consultants, consultants by name/resume or compensation amounts. However, we acknowledge Federal regulations cited by the Auditor. Questioned Costs: None Corrective Action: ? FHI will search SAM.gov for suspension and debarment of contractors and keep those records on file. FHI will perform this search annually as the contractors registration expires and is renewed. ? FHI will perform an annual self-certification that includes a justification, clear identification of the threshold, and supporting documentation to allow for $50,000 as the micropurchase limit. Name of Contact Person: Person responsible for completing the corrective action plan is Nicole Mast, Director of Operations, nmast@flowerhill.institute. Projected Completion Date: December 31, 2023 Oversight: Contractor documentation will monitored annually to ensure compliance through the end of the current contract (currently March 2026).

FINDING: 2022-004 Name of contact person: Bruce Peterson, Supervisor Corrective Action Plan: We have drafted a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200.326 that has been approved by the Township board on June 12, 2023. The policy has been submitted to the Township attorney for review, and will be finalized pending any modifications or recommendations by our attorney. Proposed Completion Date: Immediately.

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 Southwest Kansas Area Agency on Aging, Inc. respectfully submits the following corrective action plan for the fiscal year ended September 30, 2022. Name and address of independent public accounting firm: Kennedy McKee and Company LLP P.O. Box 1477 Dodge City, Kansas 67801 Audit period: October 01, 2021 through September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - Major Federal Award Programs Audit U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Title III Aging Cluster Title III B Supportive Services CFDA 93.044 Title III C Nutrition Services CFDA 93.045 Title III C Nutrition Services Incentive CFDA 93.053 Grant Period: Year ended September 30, 2022 Condition: The Organization did not have a written procurement policy to properly implement all the requirements of 2 CFR Section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Criteria: In accordance with 2 CFR Section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR 200.318 through 200.326 of the Uniform Guidance. Cause: The Organization?s procurement policy does not incorporate all the requirements of 2 CFR Section 200.318 through 200.326 of the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. Southwest Kansas Area Agency on Aging, Inc. Corrective Action Plan February 9, 2023 Recommendation: Management should continue to develop comprehensive written policies and procedures to administer all federal programs. Current written policies should be evaluated for inclusion of and compliance with Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements. If the Oversight Agency has questions regarding this plan, please call Rick Schaffer at (620) 225-8230. Sincerely yours, Rick Schaffer Executive Director 236 San Jose Drive Dodge City, KS 67801

Procurement of professional services for all federally funded projects will take place immediately. Police Jurors have been fully advised of the requirement and commit to adhering to the policies and procedures.

Recommendation: The Auditor noted the Organization should consider implementing policies, procedures, and internal controls specific to federal awards which are in writing and are approved by the appropriate level of management or those charged with governance. Planned Corrective Action: Management agrees with the recommendation and has implemented the following steps. A procurement policy, compliant with the Procurement Standards codified in 2 C.F.R. ? 200.317 through ? 200.327 has been approved by the Board of Directors. This policy states the procedures required for documentation for procurement of goods and services related to all Federal awards. Specific additional procedures have been implemented providing an additional level of review for all Federal expenditures, including a quarterly reconciliation of reporting submitted to the granter.

2022-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2023 Corrective Action: Management agrees with the finding and recommendations set forth within and is nearing completion of its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. The updated procurement policy is scheduled to be released during the third quarter of the fiscal year 2023. Training on the Uniform Guidance procurement requirements has been developed and will be required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. Last, during the first quarter of the fiscal year 2023, NeighborWorks implemented a new contracts management system that will be used to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. Full transition to the new system is targeted for the end of the fiscal year 2023.

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

DHS agrees with the finding and recommendation. DHS will remind staff via electronic memoranda to ensure compliance with federal and County procurement requirements and maintain records sufficient to detail the history of the procurement.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number: 317-485-3100 Views of Responsible Official : We concur with the finding Description of Corrective Action Plan: The Food Service Director (FSD), with assistance from the CFO, will develop a plan to secure a third vendor for kitchen equipment repairs, both for emergencies or regular maintenance repairs. The FSD and CFO will also develop a plan to solicit service plan proposals from qualified providers. The FSD and CFO will utilize approved service agreements through purchasing cooperatives, if available or, solicit responses through the public works bidding process. If a responsive responsible bidder can be secured, the service contract will be approved by the school board of trustees. Anticipated Completion Date: 7/1/2023

Finding Number: 2022-003 Planned Corrective Action: The district will put procedures in place to ensure that all future purchases with federal funds follow the board policy for federal procurement. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Sandi Hurd, Treasurer

Finding Number: 2022-002 Planned Corrective Action: The district will improve internal controls to ensure that all contracts utilizing federal funds will adhere to both state and federal procurement guidelines as well as the School District?s procurement guidelines. Anticipated Completion Date: 6/1/2023 Responsible Contact Person: Adam Quirk, Treasurer

2022-004 INTERNAL CONTROL OVER COMPLIANCE AND COMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT The National Trust has a Procurement SOP that is fully responsive to CFR ?200.318, and the sampled expense complied with that policy when procured in April 2022. Federal funds were awarded in July 2022 permitting reimbursement of costs incurred as early as March 2021. At the direction of pass-through entity Westchester County, these one-time coronavirus relief funds were applied to reimburse the National Trust for expenses selected by that entity even though the vendors were contracted prior to the award of relief funds. To remedy any gaps in our process, the National Trust will modify the Procurement SOP to clarify that multiple contracts with a single vendor must be treated as a single contract for purposes of the small purchase threshold and will ensure that all expenses are subject to the more stringent requirements under CFR ?200.318. Additionally, the National Trust will modify the procurement procedures to ensure that suspension and debarment screening occurs prior to entering contracts. Individual(s) Responsible for Corrective Action Plan: Thompson Mayes Chief Legal Officer and General Counsel 202-588-6182 Anticipated Completion Date: June 30, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.