Corrective Action Plans

Context: For the three small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $127,299 in FY23 and $25,354 in FY24 for contracted rehabilitation therapy and speech pathology services. Additionally, the School Corporation did not perform suspension and debarment checks on the sample vendors Contact Person Responsible for Corrective Action: David Rowe, Business Manager, and Ashleigh Allison, Director of Exceptional Learners Contact Phone Number: 765-298-6505 (David), 765-298-6410 (Ashleigh) Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Acquire and document quotes/bids from the necessary number of vendors for projects requiring bids. In addition, suspension and debarment checks will be performed on the sample vendors, with documentation of the checks being maintained. Anticipated Completion Date: Begin immediately, ongoing.

Finding 2024-002- Moving to Work Demonstration ALN 14.881 - Procurement- Formal Competitive Requirements - Noncompliance & Significant Deficiency Noncompliance & Significant Deficiency Movingto Work Demonstration - ALN #14.881 Corrective Action Plan: We will have staff attend procurement training to stay connected with guidelines. We will also update our procurement policy in this fiscal year. Although we received prices for different properties, we did not anticipate, nor have we ever done roof replacement collectively for our entire portfolio. It is not uncommon to obtain pricing based on the remaining useful life of the roofs as they were not initially installed at the same time in the past. Also, as part of capital improvement planning, we consider each properties need of priorities accordingly. Person Responsible: Richard Brockington Anticipated Completion Date: June 30th, 2025

Susquehanna Township School District respectfully submits the following corrective action plan for the year ended June 30, 2024. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule: A. Compliance Findings Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Recommendation: The Subrecipient must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials and Corrective Action Planned: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now. Person Responsible: Oslwen C. Anderson, Jr., Business Manager OCA Completion Date: June 30, 2024

RESPONSIBLE OFFICIAL: SHERI PATTERSON, BUDGET & FINANCE DIRECTOR Management understands that Hood River County, as a Federal Grant recipient and a public servant, should follow formal procurement methods. The policies are in place for the County. Updates will be made in 2025 to strengthen these policies. Management will work to enforce these policies through all departments and divisions.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559, and 10.582 Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Purchasing procedures and thresholds were discussed at a leadership meeting of the Department of Food and Nutrition Services. Specifically, the need for at least two quotes for purchases between $15,000 and $50,000 was reiterated. On an ongoing basis, expenditures by vendor will be reviewed to ensure compliance with the procurement policy. Name of the contact person responsible for corrective action: Jaime Hetzler, Director of Food and Nutrition Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

In the future, we intend to advertise for a longer period of time and if needed re-advertise for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward management will be mindful of established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Name of the contact person responsible for corrective action: CFO Planned completion date for corrective action plan: January 1, 2025

2024-005 Procurement – Child Nutrition Cluster Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to our commitment to optimizing procurement practices, we have undertaken a review of our policies and procedures in accordance with Uniform Guidance and the District's Purchasing Policy. As part of this effort, we've already implemented several key enhancements to ensure that our procurement processes align with regulatory standards and organizational policies. Moreover, we've conducted an evaluation of current procedures and controls to promote consistent adherence to policies. Efforts have been made to ensure that all transactions are properly documented in accordance with district policies. These proactive measures aim to enhance our procurement framework, improve compliance, and reinforce transparency. By implementing these recommendations, our district is working towards creating a more robust and accountable procurement system, aligning with both regulatory guidelines and internal best practices. Ongoing efforts will focus on continuous improvement to further strengthen our procurement processes. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2025

Finding 2024-002 – Child Nutrition Cluster – Procurement Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An RFP will be conducted for the technology support. Anticipated Completion Date: Summer 2025

CORRECTIVE ACTION PLAN Finding 2024-001 Personnel Responsible for Corrective Action: Julie Turck, VP of Finance & Admin Anticipated Completion Date: December 31, 2024 Corrective Action Plan: LFSRM will develop a procurement policy along with procedures to follow, which will include a process of approving vendors that will be used for varying levels of purchases along with a plan to document and store quotes received and the reasoning behind the choice of vendor. Along with this there will be a plan for checking eligibility of vendors on Sam.gov.

Condition: The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements. Planned Corrective Action: This finding was due to the District having turnover among key personnel in the grants area, as well as non-adherence to policies and procedures related to grant records, grant accounting, and year-end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file. Contact person responsible for corrective action: Rusty Williams, Interim Financial Officer Anticipated Completion Date: March 31, 2025

January 5, 2024 To: Nigro & Nigro PC Regarding Audit Finding 2024-001 Procurement (5000) Assistance Listing #10.533, 10.55- U.S Department of Agriculture, California Department of Education, Child Nutrition Cluster We agree with the auditor's comments and the following actions will be taken to ensure the district is compliant with Code of Federal Regulations, CFR 200.320. 1) Implement a district system to track all formal bids, informal bids and RFQ's by contract year 2) Documents will include key information such as bid solicitation dates, contract dates and renewal dates for all Nutrition Services bids, RFPs, RFQs and micro-purchases. 3) The Director of NUtrition Services will review all contracts at the beginning of each school year. These steps along with training key personnel will make sure we are in compliance with Code of Federal Regulations, CFR 200.320 Michelle Cagle Director, Fiscal Services

Finding 2024-003 Procurement, Suspension, & Debarment Significant Deficiency in Internal Control over Compliance Criteria Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.591 Program Name: Family Violence Prevention and Services/State Domestic Violence Coalitions Finding Summary: 2 CFR 200.303(a) establishes that the auditee must create and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. There were two instances where the review and approval process did not identify the procurement worksheet was incorrectly completed. In addition, the contracts tested did not include some of the required contract provisions. Corrective Action Plan: Completed. Management agrees that the procurement worksheet was incorrectly completed, and training has taken place with agency staff to ensure accurate completion of the required documentation. Responsible Individual: Krista Heeren-Graber, Executive Director Anticipated Completion Date: Completed

Finding Number 2024-001 Contact Person(s): Jonathan Smith, Director of Finance R ecommendation: Subsequent to June 30, 2024, we noted the Organization requested and received explicit approval from the United States Department of State to use the noncompetitive procurement method for the procurement transaction tested. We recommend that the Organization implement measures to ensure that proper justification be determined and documented when utilizing the noncompetitive procurement method for the procurement transaction tested. C orrective action planned: Landesa will work to train program staff on non-competitive procurement use cases, and the documentation required to support these type of transactions. Additionally, Landesa will implement procurement software to automate workflows and approval processes for non-competitive procurement. Anticipated completion date: January 2025

Response to Finding 2024-001 Federal Award Agency: Department of the Treasury Name of Contact Person: Geoff Wall, Chief Financial Officer Views of Responsible Officials: The housing authority did follow its standard procurement policy and obtained 3 qualified bids from General Contractors before executing the contract. As a subrecipient of the ARPA funding staff believed our procurement processes were sufficient. After the contract was executed, staff discovered that the requirement for sealed bids under 2 CFR 200.320 of the Uniform Guidance was passed through in the subrecipient agreement. Corrective Action: 1. The Director of Development and the Chief Financial Officer for the Authority will review grant agreements and subrecipient agreements for all sources of funding for construction/development projects prior to hiring a general contractor in order to confirm the most restrictive requirements for procurement are being followed. Date of Planned Corrective Action: Immediately following being notified of this finding.

2024-005 Suspension & Debarment Recommendation: CLA recommends the City continue the process in assessing its financial management systems and related internal controls over federal awards during the 2025 fiscal year. This assessment should include evaluating existing policies and procedures to determine where additional enhancements should be made or new policies created, a plan to communicate these policies to City employees, and procedures to periodically review and update, as considered necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The City has implemented procedures to ensure vendors are being checked for suspension and debarment prior to entering into contracts. Name of the contact person responsible for corrective action: Michael Stelmaszek, City Manager Planned completion date for corrective action plan: June 30, 2025

Management agrees with the finding that two out of five procurement selections totaling $158,000 did not include the appropriate evidence (signed competitive bid or sole source justification) and that this information was not retained in the procurement file. While the departments that selected the vendors did perform sole source and vendor evaluation within their departments, formal documentation and appropriate sourcing details was not obtained by CHOP Procurement. As CHOP is committed to full compliance with reporting requirements for all external agencies, our organization has determined that putting additional controls and education into place with our staff members is the appropriate action to take. Therefore, we will be conducting formal training in November 2024 to our Purchasing and Contracting teams to ensure all established procurement processes and policies are adhered to. Additional auditing of CHOP purchases meeting the bid threshold will be conducted on a monthly basis by the CHOP Procurement Manager and AVP, Sourcing, Contracting, and Procurement. Any discrepancies will be identified and addressed following the audit. CHOP commits to an improved management and oversight of these requirements going forward. Jeffrey Raup, AVP – Sourcing, Contracting, and Procurement at CHOP, will have responsibility for this corrective action plan.

Finding: 2024-002 - Procurement, Suspension and Debarment Auditor Description of Condition and Effect: In cases where the vendor did not sign a suspension or debarment certification, either within the vendor contract or as a separate certification, the City did not have a process in place to manually search the Excluded Parties List System to verify the vendor was not suspended or debarred. As a result of this condition, while none of the vendors tested appeared to be suspended or debarred, documentation does not exist to support that the City verified its vendors paid with federal dollars were not suspended or debarred prior to contracting with them. Auditor Recommendation: We recommend that the City create procedures and a related checklist to ensure all federal requirements are being addressed. Corrective Action: Due to the influx of new employees managing federal funds under the Coronavirus State and Local Fiscal Recovery Funds program, many were unaware of the requirement to document their searches for suspended or debarred vendors. As a result, search results showing no matches were not retained in the files. Moving forward, all relevant employees will receive additional training to ensure proper documentation of these searches. This training will help to ensure this requirement is consistently met in the future. Responsible Person: Heather Ehnis, Finance Director Anticipated Completion Date: June 30, 2025

Procurement, Suspension, Debarment Description of Finding: The Board of Education failed to document sole source justification prior to awarding contracts to vendors. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will review existing processes and contracts to ensure procurements are taking place in compliance with local policies and federal guidance. Name of Contact Person: Joshua Pothier, Comptroller Projected Completion Date: June 30, 2025

There is no disagreement with this finding. The District does have an appropriate Procurement policy in place. The District has already begun reviewing policies and procedures to ensure that documentation related to procurement is consistently documented in accordance with District policy.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORETABLE INSTANCES OF NONCOMPLIANCE– U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2024-001 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Finding Summary - 2CFR § 200.320 requires the District to establish and maintain effective internal control over compliance with procurement requirements applicable to its federal program expenditures. Our testing indicated that the District did not have sufficient controls in place within its special education cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable instances of noncompliance where contracts exceeding the District’s micro purchase threshold were awarded without obtaining multiple quotations for two of six vendors tested. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to relating to procurement for its special education cluster federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. Official Responsible – The District’s Director of Finance, Joseph Primus. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance will monitor the implementation of these corrective actions, and will verify that appropriate controls over federal procurement requirements are in place and being consistently applied to ensure multiple quotations are obtained for contracts awarded for goods or services in excess of the District’s micro-purchase threshold, as required by the Uniform Guidance.

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2024 FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation's policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation's contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the School Corporation's procurement policy is being followed for all procurement thresholds. Management will perform a periodic check of federal fund disbursements to see if any vendors exceed procurement or suspension and debarment thresholds on an annual basis to ensure compliance with federal and state procurement guidelines. The School Corporation will ensure that all contracts exceeding $25,000 include a suspension and debarment clause and will verify that the vendor is not suspended or debarred prior to entering into the contract. Responsible Party and Timeline for Completion: The Food Service Department has already implemented these changes as the issue was not present in fiscal year 2024.

CONTACT PERSON: Jessica D. Carraher, Associate of Financial Services, Charleston County School District, jessica_carraher@charleston.k12.sc.us CORRECTIVE ACTION: The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds. PROPOSED COMPLETION DATE: June 30, 2025

Re: Finding 2024-001: Procurement (50000) Nutrition Services currently uses US Foods for the purchase of various commercial food items throughout the year (candy, chips, soda, bread, hotdogs, popcorn, coffee, hot cocoa, churros, cookies, etc). A vast majority of the purchases are for non-program foods for catering or Snack Bar Sales at Fred Kelly Football Stadium. Occasionally, US Foods is used to purchase specialty items for students with food allergies (i.e. gluten free) and baby food for students that require a pureed diet. Nutrition Services compares prices between US Foods and Smart and Final periodically throughout the year. Smart and Final purchases are made in store and Nutrition Services would have to provide pictures of price tags on the shelf at Smart and Final to show compliance with this request. Nutrition Services requested a price quote for products purchased through US Foods. Unfortunately, the company representative told us their prices are variable based on the market and could change weekly. Nutrition Services would only be able to provide auditors of screenshots ofUS Foods online ordering portal, which would consist of hundreds of pages given the expansive foods available. To correct the finding, Nutrition Services will do the following: 1. Request piggybackable formal bid options from US Foods. To that end, the Nutrition Services and Purchasing directors will seek board approval no later than March 1, 2025. 2. Take necessary steps to increase micropurchase threshold to $50,000. 3. Consider opening a Purchase Order with Sysco Foods to spread the micropurchases to another online retailer, thus mitigating the issue of in-person shopping and price comparisons. 4. Work with Purchasing Department to ensure open Purchase Orders do not exceed $50,000 for any vendor that does not have formal procurement in place. To that end, the Nutrition Services Accounting Technician and the Purchasing Supervisor will review quarterly expenditures for all open purchase orders effective December 1, 2024.

2024-005 Higher Educational Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All grants at NEO have been instructed about the importance of submitting sole source support for purchases where needed. The VP of Fiscal Affairs will ensure proper documents are submitted to justify purchases before approvals are done in OK Corral. Name(s) of the contact person(s) responsible for corrective action: Brando Glick, VP Fiscal Affairs Planned completion date for corrective action plan: 11/30/24