Corrective Action Plans

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotes for vendors exceeding $10,000 from three sources. These will be reviewed and initialed by the Business Manager. For vendors with total disbursements expected to be between $50,000 and $150,000, the Food Service Director will obtain contracts from the vendors and these contracts will be stored at our Central Office. DeKalb Eastern will confirm with the Education Service Center via email or letter that the Service Center is correctly certified with the state for procurement requirements. 1f the Education Service Center remains uncertified, the Food Service Director will obtain price or rate quotes for milk from three sources. These quotes will be reviewed and initialed by the Business Manager. The Food Service Director will request a certification from vendors with contracts over $25,000 to show they are not excluded from participation in federal award programs. In the event the vendor is unable to provide a certification, DeKalb Eastern will utilize the SAM website to view the exclusions list of vendors . Anticipated Completion Date: Ongoing - The Food Service Director will obtain the necessary price and rate quotes, as well as contracts and certifications and the Business Manager will review and initial the quotes.

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate

2022-004 Coronavirus State and Local Recovery Funds ? Assistance Listing No. 21.027 - Procurement Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Finance Manager will implement a Federal Procurement Checklist. The Finance Manager will provide the checklist to the finance committee to complete and approve for federal spending. Name of the contact persons responsible for corrective action: Jill Johnson, Finance Manager, and Department Heads and Elected Officials Planned completion date for corrective action plan: December 1, 2023

2022-001 Methods of Procurement Recommendation: We recommend that the County review their policies and procedures to ensure that they are operating in a manner that follows federal procurement requirements and the County?s procurement policy. The creation and use of a standard procurement checklist would assist the County in documenting all requirements for each procurement that is entered into. Management Concurs with the Finding and Recommendation Action Plan Taken in Response to Finding: The Finance Department will work with County Management and Board Departments to ensure familiarity and understanding of the County?s procurement policies and procedures. Additionally, the County is working towards the implementation of a financial system which will improve the controls in place to help ensure compliance with procurement requirements. The Finance Department is also working on a financial policies document and will would with County Manager on a review of the County?s procurement policy. Name(s) of contract person(s) responsible for corrective action: Tasha Morgan, Finance Director Planned completion date for corrective action plan: We anticipate the finding will be address by September 30, 2023

U.S. Department of Treasury 2022-004 COVID-19 ? Coronavirus State and Local Relief Funds (CSLRF)? Assistance Listing No. 21.027 Recommendation: The Town should review and enhance controls and procedures to ensure that it follows procurement policy for all goods and services charged to the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Town's procurement policy will be reviewed and updated to ensure compliance with federal requriements. Name(s) of the contact person(s) responsible for corrective action: Steven Repole Planned completion date for corrective action plan: 6/30/2023 If the U.S. Department of Treasury, Office of Recovery Programs has questions regarding this plan, please call Steven Repole at 410-398-4170.

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023

The City of Dos Palos was on a state of emergency Resolution, and when these funds came available, understood that we could go forward with the rehabilitation of our 750,000 gallon tank, for storage for the City. In the future, if an emergency situation should arise, the City will review all regulations and documents for procurement of the funds. The City's procurement policy is outdated and we will be implementing a new written procurement policy.

Condition: In 2 of 4 sample selections of vendor purchases, the City was not able to provide evidence of properly following the procurement policy for federal awards. In 1 of the 2 failed instances, the City inappropriately designated a vendor as sole source. In 1 of the 2 failed instances, the City was unable to produce documentation for the simplified acquisition threshold related to small purchases to show procurement by sealed bids and competitive proposals. Cause: Failure to follow Federal procurement regulations. Effect: Procurement support was unavailable to demonstrate the procurement policy was followed for a vendor and an inappropriate use of sole source designation for a vendor. Recommendation: We recommend the City adhere to Federal procurement policies for federal awards to ensure proper procurement standards are followed and adhere to allowable sole source designations.

Finding 2022-001 Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Corrective Action Plan: This was a result in a change of leadership. Staff has implemented procedures to start procurement files for each department endeavor they partake in to meet the requirements in 2 CFR, section 200.319. Anticipated Completion Date: Completed Contact Information: Keith Buday, Assistant Superintendent for Finance & Operations budayk@holliston.k12.ma.us

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

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

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

The Town of Clinton/School Department will maintain proper procurement procedures in compliance with Local, State and Federal laws and regulations. State procurement laws (MGL Chapter 30B for Goods and Services and MGL Chapter 149 Construction) are followed however the district is aware of the federal requirements. When there are exemptions from state procurement laws, of when federal regulations are stricter the district will use the strictest rules, under 2 CFR 200.318-327. These procedures have been updated in the Financial Procedures Manual (pages 231-240, under Section II Procurement System). The Town of Clinton/School Department will utilize two methods to determine if a potential vendor has been suspended or disbarred. Prior to approving a requisition for a contracted service in excess of $25,000 funded by a Federal grant, district will check Sam.gov and will require the vendor to sign an affidavit. The Town of Clinton/School Department will expend membership with French River Education Center - Purchasing Cooperative to include several school lunch food products.

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

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

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

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

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

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

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.

That the Borough follow the DGLS guidelines for purchases over $44,000, which includes publicly advertising for sealed bids on contracts over $44,000. The Police Chief with the Purchasing agent will bid next time this situation presents itself.

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.