Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: The Organization will review procurement policies and procedures to address the recommendation noted. The Organization will also ensure that all documentation for procurement is saved in a central location digitally to ensure documentation is complete in the Organization’s records for all procurement decisions made.

MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is during the start of the 2023-2024 fiscal year and continuing forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately.

First, although all purchasers are required to complete training on purchasing and payment policies prior to obtaining system access, a refresher policy training will be provided to the 13 departments in which exceptions were discovered along with a reminder communication to all the approximately 4,300 department purchasers. This will be completed by June 30, 2024. Second, for certain types of purchases such as those involving intellectual property rights, suppliers may complete work in good faith and request payment in the absence of a purchase order or contract. A new procedure has been instituted requiring the department/supplier to execute a contract prior to payment in order to minimize legal risks to the University and its funding agencies. This new procedure is complete. Finally, we are analyzing legitimate uses of the OPRS form and evaluating whether placing a maximum dollar limit, such as $5,000, for the use of the form will further strengthen internal controls. The evaluation will be completed by June 30, 2024. Implementing maximum dollar limits on the OPRS form will require IT changes, and therefore implementation will not occur until December 31, 2024. Anticipated completion date: Various completion dates noted above in the corrective action plan. Names of contact person(s) responsible for corrective action: Stephanie Ford-Jones, Director of Payment Processing and Compliance

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (Or Other Identifying Number): 19611-067-PN01, 20611-070-PN01, 21611-070-PN01, 22611-02-CEIS, 22611-070-PN01, 22611-070-ARP, 23611-067-PN01, 21619-070-PN01, 22619-070-ARP, 22619-070-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreements 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 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. For fiscal year 2022, the School Corporation had one vendor, with disbursements totaling $199,713 for the fiscal year, which exceeds the simplified acquisition threshold of $150,000. 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. For fiscal year 2022, three vendors, totaling $228,079, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold. One of the three vendors was selected for testing. 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. For fiscal year 2023, one vendor, totaling $65,861, was identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold and was selected for testing. 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 were systemic issues throughout the audit period. 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 six vendors identified which exceeded $25,000 in disbursements on an annual basis. Two vendors were selected for testing. In both instances, 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 systemic issues throughout the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Specifically, regarding Suspension and Debarment, for contracts over $25,000, MSD of Pike Township will obtain a Certification or include a Suspension and Debarment clause in the contract. Absent Certification, the Director of Grants will review for “Suspension and debarment” and maintain documentation. The Special Education Department will work with the Grant Manager and will review contracts over $50,000 to follow the appropriate procurement policy to obtain quotes. Where specialized services are being solicited, we will maintain a procurement file memo documenting the process and the reasons for vendor selection. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan. Plan will be implemented by June 30, 2024.

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH agrees with this finding and recommendation and will discuss, and document sensitive legal matters funded by federal funds with respective grantors to obtain guidance and direction on addressing audit requests. DPH will implement a protocol wherein the program executing any contract using federal funds will collect and maintain sufficient records which detail the history of the procurement. The program will also verify that compliance with procurement requirements is maintained for all federally funded contracts, including sufficient documentation to demonstrate compliance with suspension or debarment. To confirm this, the program will check the SAM exclusions prior to entering into a contract and will maintain documentation of that verification. These will ensure DPH’s ability to provide documentation when requested by auditors. 3. Anticipated implementation date: July 1, 2024

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH, Acute Communicable Disease Control (ACDC) agrees with the finding and recommendation. Before entering into contract, DPH will check for SAM exclusions with date indicating verification before contract execution and keep this documentation on file. DPH, Administrative Services Division (ASD) - Procurement agrees with the finding and recommendation. DPH’s Administrative Services Division Manager will email Procurement staff to remind staff/manager to ensure SAM.GOV verification documents are included in all federally funded purchases before finalizing/approving those transactions. 3. Anticipated implementation date: March 11, 2024 and April 30, 2024

The City concurs with the second instance in which the City exceeds the $50,000 threshold required for the method of procurement for Micro-Purchases. The City corrected the public works contract template using federal funds not to exceed $50,000 and has updated the City internal website to reflect the updated contract templates and provide guidelines for public work projects using federal funds under the micro-purchase thresholds. For the first instance, the City believes some form of self-certification was performed as the procurement policy was updated and reviewed by internal management level and was approved by the council in FY2023. However, moving forward, the city will include an approved annual memo on the review of the purchasing policy to further strengthen the self-certification documentation.

Description of Corrective Action Plan: Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. To ensure compliance with competitive procurement documentation requirements, EmployIndy will review and update, as necessary, its procurement processes, reflecting that in cases where competitive procurement of a vendor is performed by a partner organization that EmployIndy receive and retain all necessary documentary support. In addition, Grants and Contracts staff will complete retraining on competitive procurement requirements. Responsible Party and Timeline for Completion: Corrective Activity Responsible Party Timeline for Completion Review and update competitive procurement procedures to ensure documentary requirements for competitive procurements performed by partners are well-defined. Associate Director of Grants & Contracts 2nd Quarter of Calendar Year 2024 Complete updated training on competitive procurement documentation requirements Associate Director of Grants & Contracts and Grants & Contracts Manager By 3rd Quarter of Calendar Year 2024 Hold Grants and Contracts staff are accountable for collecting and retaining required documents in scenarios where a partner completes competitive procurement of vendor(s) used by EmployIndy Executive Vice President of Finance and Operations Ongoing

Ref 2023-006: Documentation needs to be maintained to justify the rationale for sole-source arrangements Federal Agency: United States Agency for International Development (USAID) for Nigeria OTL Program: Nigeria OTL Assistance Listing: 98.001 (Nigeria OTL) Award #: 72062021CA00006 NGA100152 (Nigeria OTL) Award year: FY23 Pass-through: Plan USA, Inc. Management comments: Management agrees with the finding and recommendation. Although a system of internal control around the procurement process was in place for such transactions, we were unable to obtain the original procurement documents. As such, management will review and/or make updates to the existing policies in place as well as provide trainings during FY24 to staff to ensure that policies are properly followed and documentation is consistently maintained. (Corrective actions will be introduced and completed by June 30, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program; Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Tiffiny Ulman Contact Phone Number and Email Address: 219-924-4250 tulman@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Establish post award internal controls surrounding grant management including, but not limited to, Procurement and Suspension and Debarment. Anticipated Completion Date: 3/5/2024

Department of Education, United States Department of Agriculture, Federal Aviation Administration 2023-004 R&D Cluster – Assistance Listing No. 84.334, 10.001, 20.109 Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi State University will make corrections to the Procurement and Contracts Manual to ensure compliance with 2 CFR 200.320. Name(s) of the contact person(s) responsible for corrective action: Jennifer Mayfield, Director of Procurement and Contracts and Jonathan Tucker, Director Sponsored Programs Planned completion date for corrective action plan: June 30, 2024 If the Department of Education, United States Department of Agriculture, or Federal Aviation Administration has questions regarding this plan, please call Jonathan Tucker at 662-325-1930.

Finding 2023-004 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation that the procurement of the CNG tank replacement project for five Orion buses exceeding the simplified acquisition threshold of $250,000 was approved by the Board. There is documentation that an invitation for bid (IFB) was released for the project, but only one bid was received, and the District awarded the contract to the sole bidder. Missing documentation includes support of the rationale to approve the contract absent evidence of full and open competition. The District was also not able to provide the request for proposal for review. Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following: • Section 200.318(a) states that “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 service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.” • Section 200.318(i) states that “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.” • Section 200.320(c) states that “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold…; (2) The item is available only from a single source; (3) The public exigency or emergency for the retirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.” • Section 200.324(a) states that “The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals.” Cause: Staff turnover at the District and the need for the project to be completed by a certain date to avoid the buses losing certification led to the lack of adequate records being maintained. Effect: The District was unable to prove it was in compliance with the Uniform Guidance regarding open competition on procurements. the buses to be operational, so not every step was documented. The awarded contract was signed on the date of a Board meeting, but the Board minutes did not document that this contract was reviewed nor approved by the Board. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management agrees with the recommendation and acknowledges the importance of complying with uniform guidance regarding open and competitive procurements. Due to key staff turnover, the District could not locate documentation for the CNG tank replacement procurement to prove compliance with uniform guidance. In addition, the reason the agreement was not brought to the Board for approval could not be determined by current staff. To address the issues, the District will review its procurement and documentation procedures in addition to establishing checklists to ensure compliance and proper records retention.

Finding 2023-005 – Special Education Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will seek competitive quotes for these services prior to the 24-25 school year. Anticipated Completion Date: 6/30/24

Finding 2023-003 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO will send a memo to all administrators identifying quote and bid thresholds. The school district will obtain at least 3 quotes or use an alternative acceptable procurement method for large purchases. Anticipated Completion Date: 6/30/24

Action taken in response to finding: As referenced in the Audit report, a comprehensive new Procurement procedure that is fully compliant with Uniform Guidance was implemented in April 2023 and has been in place and utilized since then. In addition, a preferred Vendor list will be generated by May 31st, 2024. This list will also be reviewed and updated at least on an annual basis, with interim revisions being done as needed. Name(s) of the contact person(s) responsible for corrective action: Matt Gehri, CFO Planned completion date for corrective action plan: April 2023 for new Procurement procedure, and May 31st, 2024 for Preferred Vendor list.

The City of Tracy, California respectfully submits the following corrective action plan for the reported findings for the fiscal year ended June 30, 2023. The findings are numbered consistently with numbers assigned in the June 30, 2023 Single Audit Report. Finding 2023-001 Procurement Policy Criteria: Non-Federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $3,500 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(c); the competitive proposals method under the conditions specified in 2 CFR section 200.320(d); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(f). Finding 2023-001 Procurement Policy (Continued) Criteria (Continued): 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(d)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR part 200, “Contract Provisions for Non- Federal Entity Contracts Under Federal Awards.” Non-federal entities had a grace period of two full fiscal years after the effective date of the Uniform Guidance before they had to comply with the procurement requirements of 2 CFR section 200. For a non-federal entity with a fiscal year-end of June 30, its effective date for the procurement requirements was July 1, 2017. However, during this grace period, non-federal entities were required to clearly document whether they decided to comply with the previous version of the applicable procurement standards or the new standards contained in the Uniform Guidance. Condition: The City has not updated its purchasing policies and procedures to bring it into compliance with the requirements of Uniform Guidance. The City has also not formally documented whether it has decided to extend its applicable date of compliance with 2 CFR part 200 to be effective beginning July 1, 2018. Context: See condition above for context of the finding. Cause: The City has not evaluated its existing procurement policies for compliance with the requirements of the Uniform Guidance. Effect: The City is not in compliance with the procurement policy provisions of 2 CFR part 200 and the Uniform Guidance. Not updating the City’s procurement policy could lead to future findings and questioned costs related to federal awards. The current audit did not identify noncompliance with direct and material compliance requirements of the major federal award program. Identification as a Repeat Finding: Yes. 2022-001. Recommendation: The City should evaluate and update existing purchasing policies and procedures in order to bring the City into compliance with the procurement policy requirements of 2 CFR part 200 and the Uniform Guidance. The updated policy should include, among other things: Finding 2023-001 Procurement Policy (Continued) Recommendation (Continued): 1. Thresholds and appropriate approval procedures for allowable federal procurement methods. 2. Written standards for how conflicts of interest involving employees engaged to select, award, and administer contracts will be governed. 3. How to ensure that contracts and awards are made only to responsible and eligible contractors and how oversight of contractor performance will be monitored. 4. How records will be maintained in order to document the history of federal procurements. Corrective Action Plan: The City is still in the process of working with an outside firm on a review of procurement and purchasing policies. The consultation includes compliance review of this standard. Anticipated Completion date: July 1, 2023 Name of Contact Person: Sara Cowell, Finance Director

2023-003: Procurement Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to document reasons for obtaining competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Accounting and Purchasing will both review requisitions within Jaggaer to make sure appropriate bids, and or exemptions are documented or attached. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: Implemented in February 2024.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: For three vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Contact Person Responsible for Corrective Action: Food Service Director, Maggie Caudill Contact Phone Number and Email Address: (812) 649-2591 / maggie.caudill@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Small Purchase Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: June 2024

FINDING 2023-006 Finding Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative). During fiscal year 2021-2022. The School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation to ensure compliance with the Procurement compliance requirement. Two vendors exceeded the small purchase threshold during the audit period and both vendors were selected for testing. For both vendors only the quote that was utilized was retained and no other audit evidence could be provided to show that additional quotes as required were obtained. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not retained for audit for either purchase. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We do not concur with the finding. Explanation and Reasons for Disagreement: The two instances cited in this finding were the results of a purchase made through the cooperative purchasing agency. Silver Creek chose this vendor that IAESC manages. IAESC serves as a governmental body in which SCSC is allowed to enter into an agreement to form a cooperative purchasing organization per IC 5-22-4-7. We can provide evidence that the cooperative purchasing agency has properly conducted an RFP for these two purchases. After reviewing the purchases for CDW Government and School Outfitters, SCSC does not recognize these as small purchases since these items were listed separately on the voucher and did not cross the threshold of $10,000.00.

􀀃 Finding􀀃2023􀍲007􀀃 􀀃 Finding􀀃Subject:􀀃Special􀀃Education􀀃Cluster􀀃􀍲􀀃Procurement􀀃 Summary􀀃of􀀃Finding:􀀃The􀀃district􀀃does􀀃not􀀃have􀀃a􀀃procurement􀀃policy􀀃outlining􀀃 procurement􀀃standard􀀃for􀀃all􀀃federal􀀃programs.􀀃􀀃Internal􀀃Controls􀀃were􀀃deficient􀀃in􀀃 preventing􀀃noncompliance􀀃and􀀃not􀀃maintaining􀀃methods􀀃of􀀃procurement.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 The􀀃school􀀃board􀀃will􀀃adopt􀀃a􀀃procurement􀀃policy􀀃for􀀃all􀀃federal􀀃programs􀀃to􀀃comply􀀃 with􀀃procurement􀀃standards􀀃and􀀃the􀀃policy􀀃will􀀃be􀀃implemented.􀀃􀀃Additionally,􀀃The􀀃 Director􀀃of􀀃Special􀀃Education􀀃and􀀃the􀀃Special􀀃Education􀀃Treasurer􀀃will􀀃ensure􀀃 procurement􀀃procedures􀀃are􀀃followed􀀃for􀀃all􀀃purchases􀀃and􀀃if􀀃the􀀃total􀀃is􀀃between􀀃 $50,000􀀃and􀀃$150,000􀀃a􀀃contract􀀃will􀀃be􀀃awarded.􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃 dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Special􀀃Education􀀃and􀀃the􀀃 Special􀀃Education􀀃Treasurer.􀀃 􀀃 Anticipated􀀃Completion􀀃Date:􀀃On􀀃or􀀃before􀀃June􀀃30,􀀃2024􀀃

􀀃 Finding􀀃2023􀍲006􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃ensure􀀃procurement􀀃 is􀀃done􀀃properly􀀃and􀀃allowed􀀃the􀀃district􀀃to􀀃enter􀀃an􀀃agreement􀀃with􀀃a􀀃vendor􀀃that􀀃did􀀃not􀀃 have􀀃proper􀀃documentation􀀃that􀀃they􀀃were􀀃not􀀃excluded.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Procurement􀀃–􀀃Region􀀃8􀀃 The􀀃Director􀀃of􀀃Food􀀃Service􀀃has􀀃the􀀃responsibility􀀃to􀀃ensure􀀃participation􀀃with􀀃IDOE􀀃 approved􀀃SFA􀀃Cooperatives􀀃only.􀀃􀀃We􀀃now􀀃utilize􀀃Food2School􀀃and􀀃have􀀃the􀀃 necessary􀀃documentation.􀀃􀀃􀀃If􀀃we􀀃consider􀀃other􀀃Cooperatives,􀀃the􀀃Director􀀃will􀀃 ensure􀀃they􀀃are􀀃approved.􀀃􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃dated,􀀃and􀀃retained􀀃by􀀃 school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃 Services.􀀃 􀀃 Procurement􀀃􀍲􀀃SACS􀀃 The􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃Services􀀃will􀀃ensure􀀃 procurement􀀃procedures􀀃are􀀃followed􀀃for􀀃all􀀃purchases􀀃and􀀃if􀀃the􀀃total􀀃is􀀃between􀀃 $50,000􀀃and􀀃$150,000􀀃a􀀃contract􀀃will􀀃be􀀃awarded.􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃 dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃 Asst.􀀃Director􀀃of􀀃Food􀀃Services.􀀃 􀀃 Suspension􀀃and􀀃Debarment􀀃 The􀀃Director􀀃of􀀃Food􀀃Service􀀃has􀀃the􀀃responsibility􀀃to􀀃ensure􀀃that􀀃all􀀃vendors􀀃are􀀃free􀀃 from􀀃suspension,􀀃debarment,􀀃or􀀃aren’t􀀃otherwise􀀃excluded.􀀃Suspension􀀃and􀀃 debarment􀀃documents􀀃are􀀃to􀀃be􀀃collected􀀃on􀀃a􀀃yearly􀀃basis.􀀃If􀀃such􀀃documents􀀃are􀀃 not􀀃available􀀃through􀀃the􀀃SFA􀀃Cooperative,􀀃it􀀃will􀀃be􀀃the􀀃responsibility􀀃of􀀃the􀀃 Director􀀃of􀀃Food􀀃Service􀀃to􀀃acquire􀀃them􀀃through􀀃SAM.gov􀀃website􀀃or􀀃contacting􀀃the􀀃 vendor􀀃directly.􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃 by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃Services.􀀃􀀃 􀀃 􀀃 INDIANA STATE BOARD OF ACCOUNTS 51 􀀃 Preparing today’s learners for tomorrow’s opportunities. 􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

Name of contact person - Mr. Joseph Gudac, Business Manager Corrective Action - We will follow our policy for federal purchases subject to quotation/bid/sole source requirements moving forward. The district will follow the policy for obtaining three quotation/bid requirements for federal purchases. In the event purchases are made through cooperative purchasing programs, three quotes will be documented when federal purchases are disbursed. We also implemented processes to improve documentation relating to the “reason” and “cost analysis” of sole source noncompetitive procurement. Anticipated Completion Date - The District will implement the above procedure immediately.

Food Worker Relief Program – Assistance Listing No. 10.181 Recommendation: We recommend that the Organization strengthen its controls and processes to identify all procurement transactions, ensure the appropriate procurement policies and levels are followed and clearly documented, and to verify vendors are not suspended or debarred. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has taken the follwing steps to ensure procurement policies are followed : 1) Management has begun the hiring process for additional staffing in the Procurement Department to help support all operations. 2) Management will review and update current policy to be in line with Federal Procurement policies. 3) Procurement department will provide training to all personnel authorized for purchases. Name(s) of the contact person(s) responsible for corrective action: Jesse Satterlee, Interim CFO, 778-730-1155 Nancy Lipman, SVP Compliance, 602-257-0700 Planned completion date for corrective action plan: 6/30/2024 – Ongoing action and Implementation

Action taken in response to finding: • LMC will provide better training for procurement procedures • Staff will retain copies of the documentation for price quotes

Finding Number: 2023‐002 Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The responsible role of Purchasing and Payables changed during fiscal year 2022‐23. The new person was not made aware of the need to perform an annual check for suspension and debarment. Training has seen occurred and a new schedule established for performing the required check of vendors over the threshold of $25,000. Also, a newly established procedure will be established to clarify Sole Source approval by the governing board for vendors.