Corrective Action Plans

Corrective Action Plan for Finding IC2022-001: Financial Reporting Accomack County understands the repeat finding regarding financial reporting. In our response in FY 21 to this comment we stated ?through the addition of one FTE in the FY 23 year, staff training in particular content areas such as financial reporting, pensions and OPEB reporting, and some realignment of duties with existing staff, we are able to continue internally prepared financial reports through the year and the Annual Comprehensive Financial Report (ACFR) properly and timely?. As an update, we have not been able to make a hire at this time, and have chosen to reformat the position to non-entry level and re-advertise in the spring of 2023. While an additional resource will be helpful, existing staff understanding of timing, and year- end financial reporting will continue to be both ongoing, and a priority. Accomack County Finance continues to consider financial reporting, including the year-end annual financial report a core competency and are open to suggestions in processes or protocols that will advance our capacity and capability in this area from Brown Edwards. As part of this response, County finance recognizes we are responsible for timely and accurate reporting which includes Accomack County Public Schools (ACPS) financial information and all other component units in the ACFR. As we are currently staffed, we do not have capacity for review of ACPS financial work through the year and have previously relied on their finance department. Unfortunately, that has caused delays, findings and revisions to financial exhibits several times at year end for corrections noted by the auditors. The County will explore options for reducing the aforementioned problems and thereby improving this issue as relates the ACPS financial information. Lastly, a component of the delay in FY 22 was the Landfill Closure/Post-closure liability in conjunction with Department of Environmental Quality. We have begun a specific time-line in coordination with the Deputy Director for Public Works, who has responsibility over the landfill and south transfer station so that finance has complete and approved cost information (through the DEQ process) prior to year-end each year, or just after year-end (timely). Responsible Official: Michael T. Mason, CPA, County Administrator mmason@co.accomack.va.us (757-787-5716); estimated completion date of not later than July1, 2023 for the new hire. Corrective Action Plan for Finding FA-2022-001: Procurement Accomack County Public Schools concurs with the need to maintain its Procurement Policy in concurrence with 2 CFR Part 200. The schools will review and update procurement policies to be in compliance. Responsible Official: Chris Holland, Accomack County Public Schools Superintendent, chris.holland@accomack.k12.va.us, (757)787-5759; Estimated completion date is not later than the May, 2023 School Board meeting.

Finding 2022-04: Procurement and Suspension and Debarment. District Response: A. The district will include termination for cause and convenience in professional services contracts. B. Alicia Young: Business Manager, Kim Hamm: Federal Programs Director and Julie Clark: Special Services Director C. July 1, 2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023

Condition: A vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: The District will implement procedures to perform procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: FY2023 Contact: Howard Barber, Assistant Superintendent of Finance and Operations

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

Item 2022-001 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits We recommend that the Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams/Amanda Myers Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation was under the assumption that the state procurement had secured the bidding/quote information for the vendor in question. Emails were given to document the ?go ahead? from our cooperative to order from the vendor. The corporation now understands that we are responsible for obtaining quotes outside of the cooperative. Anticipated Completion Date: Implemented immediately.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

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.