Corrective Action Plans

April 15, 2024 Donovans CPA www.cpadonovan.com RE: Findings 2023-001 Procurement Assistance Listing Number 84.282A Dear Sirs; Lawrence County Independent Schools has implemented the following Corrective Action Plan in response to the finding of the Single Audit for fiscal years ending 2023. Corrective Action Plan 1. The LCIS Procurement Policy has been updated by the Director of Schools, Joanne Symcox, under the non-Federal entity (Per 2 CFR 200.318) to conform to procurement standards identified in 200.317 through 200.327. 2. The updated policy will be presented at the March 21, 2024 Board Meeting for review and approval. 3. The corrective action plan was implemented beginning Mar 13, 2024. 4. The Director of Schools, Joanne Symcox is responsible for plan implementation and adherence. Sincerely, Joanne Symcox

Finding Number 2023-001 Contact Person(s): Rick Johnson, VP of Finance and Administration Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Corrective action planned: The Seattle Aquarium will provide training for employees involved in procurement exceeding the simplified acquisition threshold to ensure they are aware of the various procurement methods and requirements. Review of the procurement process by the Finance Department will be required for such planned purchases. Anticipated completion date: June 30, 2024

2023-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2024 Corrective Action: Management agrees with the findings and recommendations set forth within. During the first quarter of fiscal year 2023, prior to the 2022-001 finding, noncompetitive procurements completed followed the prior procurement policy that did not align with Uniform Guidance as relates to noncompetitive procurement justifications. The Corporation has since completed its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. Training on the Uniform Guidance procurement requirements was developed and 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. Moreover, 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. During fiscal year 2024, management has continued its response to the recommendations by engaging with technical experts to enhance the contracts management system and strengthen internal controls. Additional training is being developed on the enhanced system and processes to ensure continued compliance with Uniform Guidance as relates to noncompetitive procurements.

Management understands that the U.S. government requires recipients of federal grants, such as Hood River County, to adhere to specific terms and conditions. The overarching requirement Hood River county must follow is the Office of Management and Budget's Uniform Adminstrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR part 200, referred to as Uniform Guidance. Hood River County is training personnel to be mindful of following this guidance when making purchases. Through monthly meetings of the Grants Committee which attempts to centralize the County's grant work. The County is also in the process of hiring a Grants Manager to bring a higher level of education and experience overall. Hood River County is already taking these steps to inform and educate personnel at the time of this audit report.

2023-002 Procurement Recommendation: Competitive quotes should be obtained and retained as a specified in the City’s procurement policies and Uniform Guidance. Non-competitive procurement (for sole source vendors) should be documented and approved prior to incurring expenses. The City should update and expand procurement polices to document competitive procurement practices for procurement less than the bid threshold. Management Response: Staff have already implemented a procurement procedure to attach all the quotes received from vendors to the purchase order. In the future when reviewing, staff will be able to see all the vendors that provided a quote and see the lowest quote was used to procure the item(s). Staff will be updating the procurement policy during the current fiscal year to expand the policy on procurement less than the bid threshold. Responsible Parties: Brittany Retherford, Assistant City Manager, Nick Walsh, Comptroller, and Mindy Brown, Assistant Comptroller Anticipated Completion Date: September 30, 2024

Corrective Action Planned: The Board will ensure compliance with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Anticipated Completion Date: The completion date is March 15, 2024 Contact Person(s): Cindy W. Parker; Chief School Financial Officer; cparker@blountboe.net

2023-004 - Procurement, Suspension, and Debarment – Internal Control over Procurement and Verification Against the System for Award Management (“SAM”) (Significant Deficiency) Condition: Community Development Block Grants-Entitlement Grants Cluster Based on the City’s formal purchasing policy, purchase orders are required to initiate purchases from procured vendors for transactions above $5,000. During our audit, we noted that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. Coronavirus State and Local Fiscal Recovery Funds We determined that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. During our audit, we also noted that there was no supporting document to indicate that the City verified the vendor against the SAM to ensure the vendor was not suspended or debarred from federally-funded programs before the contract was entered into. Management concurs. Corrective Actions: The City has an existing purchasing policy and procedures that require documentation for all purchases. Finance department has sent to all department heads reminder and the importance of compliance with the policy and procedures. The reminder also emphasizes the necessity of preparing a purchase order before procuring products or services from a vendor. There may be certain circumstances preventing the preparation of a purchase order prior to procurement, such as the nature of the services or the urgency of acquiring materials and supplies, departments may proceed with the procurement as long as the services or purchases are within adopted budget. City Council approved the Federal Award Management Policy & Procedures on agenda item #4 on December 6, 2023. Finance staff has also updated the requisition form to include a verification of SAM.gov clearance, requiring any backup indicating the vendors status if it is federally funded. City staff has been diligently verifying the suspension or debarment for all federally funded expenditures. Implemented Name of Responsible Person: Robert A. López, Chief of Police Manuel Carrillo Jr., Director of Recreation & Community Services Ron Garcia, Director of Community Development Sam Gutierrez, Director of Public Works Rose Tam, Director of Finance Albert Trinh, Accounting Manager Projected Implementation Date: All actions needed have been Immediately implemented.

Action taken in response to finding: Management will create a process for creating and maintaining an approved vendor list as suggested. Name(s) of the contact person(s) responsible for corrective action: Christopher Dons, Chief Financial Officer Planned completion date for corrective action plan: September 30, 2024

Finding – Internal control deficiencies over procurement requirements Name of contact person: Lane Millar, Finance Director Corrective action: The City will ensure that employees receive comprehensive training on procurement requirements as a prerequisite before undertaking those responsibilities. Proposed completion date: March 1, 2024

The County is continuing to implement a county-wide contract clause that will be added to covered transaction contracts to comply with 2 CFR 180, to ensure covered transactions receive verification that the person or entity is not excluded or disqualified. Review and approval of this suspension and debarment verification will be performed during the contract approval process, which will include this standardized clause. The County’s purchasing policy and procedures manual will be updated to include this standard suspension and debarment verification process to ensure this procedure is communicated county-wide and followed. Additionally, the County will develop standard justification forms to document method of procurement to be maintained in the procurement file. The County will also update its contract templates to include applicable suspension and debarment attestation language which meets Federal requirements and update its purchasing policy and procedures manual to reflect these changes.

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

CONDITION: During my review of The School District of the City of Jeannette’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, or 2) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors – Grade Point Resources ($74,503.17) and VLN Partners, LLP ($52,750.00). CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $$22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding.

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: Procurement procedures not met – Suspension and Debarment not verified Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools was under the impression that since Sodexo was the vendor for the purchases, the contract between Washington Community Schools and Sodexo was sufficient. Going forward, WCS will obtain contracts directly from the retailer even when Sodexo is the vendor in WCS files. If Sodexo makes purchases on behalf of WCS, they will obtain quotes from three retailers. WCS will request and maintain the quotes obtained by Sodexo. WCS will also check for any suspension and debarment for any vendor that Sodexo uses to purchase items for WCS. Anticipated Completion Date: 02/01/2024

FINDING 2023-008 Finding Subject: Special Education Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. 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 $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation had not designed or implemented a procurement policy for the purchases in the audit period. In addition, the school corporation did not award a contract for a purchase of $75,387. 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. The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. One covered transaction that equaled or exceeded $25,000 was identified and selected for testing. Transactions to the vendor totaled $75,387; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 50 Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for Procurement and Suspension and Debarment. For covered transactions, the School Corporation is required to verify that the person with whom they wish to do business with is not excluded or disqualified. In Fiscal Year 2022, there was one vendor where the School Corporation had one covered transaction in the amount of $55,285, and in Fiscal Year 2023, there were two vendors where the School Corporation had four covered transactions in the amount of $130,257. During testing and inquiry of the School Corporation, it was determined that for all three vendors who had a total of five covered transactions in the amount of $185,542 during the audit period, the School Corporation did not verify if they were excluded or disqualified prior to entering into a covered transaction. In Fiscal Year 2022, the School Corporation purchased a box truck in the amount of $55,285; however, the School Corporation did not award a contract to the vendor per Indiana Code and the School Corporation was unable to provide supporting documentation to support that three quotes were obtained prior to purchasing the box truck. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

Manuals with respect to Procurement procedures will be updated to reflect proper regulation requirements. Also, training will be reinforced with respect to personnel working with purchase procedures to ensure everyone involved in the process is aware of all applicable regulations.

Assistance Listings number and program name: 10.691 Good Neighbor Authority Contact persons: Lucinda Andreani, Deputy County Manager and Flood Control District Administrator Anticipated completion date: June 30, 2025 Concur. The Coconino County Flood Control District (FCD) acknowledges price was not considered as a factor for contractor selection in the procurement of construction services for the Good Neighbor Authority program in accordance with 2 CFR 200 Subpart D Procurement Standards. A procurement was completed for construction-manager at-risk (CMAR) services, authorized by A.R.S. 28-7366, because the FCD believed at that time that the method would also satisfy the federal standards. The CMAR method bases selection on qualification and competence, does not allow for pricing to be requested or considered before making the selection, and transfers the risk of budget overages to the contractor by agreement to a Guaranteed Maximum Price (GMP). After selecting the contractor for Good Neighbor Authority construction projects, the FCD worked closely with the County’s contracted engineering firm to ensure that the GMP was reasonable and cost efficiencies were identified and implemented throughout all stages of the project. The County believes the prices paid as a result of the procurement are reasonable and no excess federal expenditures were made due to the non-federal procurement method that was used in error. FCD fiscal and management staff will receive formal training on 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, also known as the Uniform Guidance, to ensure its requirements are understood. Additionally, the FCD will implement written internal procurement procedures to be used for future procurements so that they are made in accordance with all applicable laws, regulations and policies. The County Finance Department has a designated grant accounting team specializing in compliance with Federal award requirements. The FCD will request technical assistance from this team prior to initiating any procurement with Federal funds to help make sure Federal regulations are considered and met. The Finance Department will provide training to all departments on Uniform Guidance requirements. Training will also be provided on the County’s procurement policies and procedures to help departments gain a complete understanding of the requirements for acquiring goods and services with federal funds. In line with the County’s decentralized finance model in which financial management staff are located within the departments, the responsibility to meet requirements specific to certain federal awards rests with the department that manages the award. The Finance Department will identify the source of funding for procurements requested by departments. Staff who are knowledgeable about Federal procurement requirements and the County’s procurement policies and procedures will review and approve the procurements involving federal awards.

At the beginning of the project the Center did not plan on using federal grant funds. At the conclusion of the project, it was determined that the project could be paid for by federal funds.

The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds. Person Responsible: Grant Principal Investigator; Assistant Vice President of the Office of Sponsored Projects; and Manager of the Office of Sponsored Projects. Targeted Correction Date: June 30, 2024.

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This procedure was implemented on a go forward basis on March 13, 2024.

Finding Number: 2023-001 Planned Corrective Action: To ensure future compliance with procurement policy the following action has/will be taken: 1. Management has developed a Service & Contract Procurement form that will be attached to purchase agreements/contracts for services that is or has the reasonable potential to meet or exceed $10,000 over the contract period. Service & Contract Procurement form contains the following information: a. Description of solicited services; b. Summary of written proposals; c. Basis for the selection of the vendor; d. If an emergency procurement for ongoing services, timeline for complete formal procurement process; and e. Date on which Board of Directors approved the service contract. 2. The entire management team received refresher training on the agency’s procurement policy on March 21, 2024; and 3. Management will solicit formal written proposals for professional accounting services by June 30, 2024. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Joni N. Chun, Executive Director

The Supply Chain Depa11ment will ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(t). • Additionally, the documentation will be approved by the Director of Special Education as well as the Supervisor of Supply Chain and retained as evidence of the internal controls over procurement. Timeline: Effective immediately Responsible Person:Amber Miller, Supply Chain Supervisor