Corrective Action Plans

Condition: During our testing we identified 5 contracts that did not have adequate documentation to support the basis for the contract price. Planned Corrective Action: Implement a new internal controls checklist, and review process, along with procurement training for all management staff involved in the procurement process. In addition, TARTA will be moving to a new accounting ERP system in early 2025 that will automate the procurement workflow process to ensure proper approval and documentation has been obtained prior to procuring products and services, eliminating errors. Contact person responsible for corrective action: James Karasek Anticipated Completion Date: 9/30/2024, and new ERP early 2025

Finding No.: 2023-012 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Areas Area: Procurement and Suspension and Debarment Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with Condition 1. Procurement records that were tested by E&Y auditors were from procurements conducted prior to GDOE’s implementation of the required certifications. GDOE had this finding in the prior year and has since made the updated changes to be standardized on all procurements exceeding $100,000. GDOE disagrees with Condition 2. In line with Title 5 of the Guam Code Annotated §5213, a “no quote” response will not be considered a positive quotation but shall be part of the procurement record, which shall further include a written record or memorandum of all solicitations and responses thereto, negative or positive, orally or in writing. In the event the agency obtains less than three (3) positive quotations and provides the attestation required by this Section, the agency may proceed with the small purchase procurement. GDOE has the required attestations on file to evidence that quotations were solicited to multiple potential vendors. Plan of action and completion date: GDOE has implemented the requirement for Byrd Anti-Lobbying Amendment certifications as part of bid submissions exceeding $100,000. All contracts now include standardized language and certification forms to ensure compliance. Plan to monitor and responsible officials: GDOE Supply Management Administrator, Carmen Charfauros, will continue to ensure that the Byrd Anti-Lobbying certification are a part of bid submissions exceeding $100,000. The IAO will conduct audits of GDOE’s formal procurements to ensure compliance.

The Auditor’s Office will work with the Commissioner’s Office and Prosecutor’s Office to implement the required policies.

Finding: 2023-009 All Programs Description of the Findings: During the review of the procurement compliance requirement related to major program, it was determined that the USWA did not have a document procurement policy in place until August 2023. Views of Responsible Official(s) and Planned Corrective Actions: While the Alliance did not have a standalone procurement policy in place until August 2023, it did have purchasing policies embedded in its Accounting and Finance Manual that covered purchases relative to our work at that time. No further corrective action is needed however policies are reviewed annually to ensure compliance under 2 CFR 200.516(a). Completion Date: August 2023 Responsible Official(s): ShaQuina Davis

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Suspension and Debarment – Allen County did not have documentation that vendors’ suspension and debarment status were verified through either a) checking the Excluded Parties List System (EPLS), b) collecting a certification, or c) adding a clause or condition to the covered transaction agreement. Procurement – Allen County did not ensure purchases between $10,000 and $150,000 had received the adequate number of quotes or documented why an adequate number of quotes was not received. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2023-004 for Suspension and Debarment, the Chief of Staff to the Board of Commissioners will check the EPLS on SAM.gov every time a contract is placed before the Board of Commissioners for signature not containing the appropriate suspension and debarment language or a county department starts a project with a vendor using State and Local Fiscal Recovery Funds (SLFRF). If a vendor is not found in EPLS, a certification will be solicited from the vendor prior to contract signing or purchase of goods or services verifying that they have not been suspended or disbarred. A new verification must be sought for every contract or purchase. Documentation will be kept on file by the Controller to the Board of Commissioners who is responsible for reviewing claims submitted for payment utilizing SLFRF. To correct Finding 2023-004 for Procurement, the Chief of Staff to the Board of Commissioners will instruct departments who may be spending between $10,000-$150,000 of SLFRF that price or rate quotations must be obtained from an adequate number of qualified sources. When departments submit a claim to the Controller of the Board of Commissioners for payment, they must also provide a cover sheet outlining a) rationale for the method of procurement, b) copies of quotes received, and c) a justification for the selected vendor. This information will be reviewed and if everything is in order, the cover sheet will be uploaded, along with the accompanying invoices, in the Workflow payment system as part of the record. Anticipated Completion Date: This CAP will be completed by December 31, 2024

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

CONDITION: During my review of Aliquippa School District’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 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors –– Houghton Mifflin-Harcourt ($509,919), Beaver Valley Intermediate Unit ($419,826), and Smart Solutions ($449,303). CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. 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), 200.320(a)(2)(i) and Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), 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, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

CONDITION: During my review of Aliquippa School District’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, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Saving Ourselves ($30,000), AGI Repair ($16,216), IXL ($19,218), Learning Systems Associates LLC ($25,425), AGC Education Inc. ($11,644), Apple ($163,505), Germ Solutions LLC ($160,070), Graham Security ($12,025), Curriculum Designers, Inc. ($27,875), RJ Rhodes Transit, Inc. ($24,845). CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. 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, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

Condition: The Authority did not utilize federal procurement requirements cited above for the tele-health services and SUD Peer Recovery Service contracted service providers utilized for the Certified Community Behavioral Health Clinics project. (no documentation for sole source, no proof that it was advertised, google search was provided from 7/24/24 is not sufficient, board cannot waive federal requirement). Recommendation: The Authority follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Summary of Finding: The School Corporation’s management had not developed a system of internal controls that would ensure compliance with procurement and suspension and debarment compliance requirement. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are working on establishing a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services. Description of Corrective Action Plan: We are working on establishing a proper system of internal control and developing policies and procedures to ensure there are appropriate procurement procedures for goods and services. We are working on a checklist for procurement for all federal grants. Moving forward we will ensure required bids and quotes are attached to the claim for payment. Anticipated Completion Date: The Anticipated date of completion for this correction is January 1, 2025.

FINDING 2023-004 Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that proper procurement procedures for small purchases were followed. Due to the lack of oversight or implemented controls small purchases paid to eight vendors totaling $180,015 were made without obtaining price or rate quotes. 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 $81,295; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The corporation will have adequate internal control in place and the corporation will develop a procedure to ensure rate or priced quotes are obtained for small purchases and ensure contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: April 2024

Management agrees with the finding. Management has drafted a procurement policy, and will enact and enforce this policy by the end of 2024. This policy will be reviewed annually to ensure that any changes in laws and regulation are reflected in internal procedures.

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization will continue to abide by its procurement policy and will check its vendors against the exclusion list on the System for Award Management website. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date October 31, 2024

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: Action steps Who At least quarterly program level review of budget vs. actuals to discuss trends, variances, potential errors in coding of transaction Finance Team and Executive Directors At least quarterly review of admin costs, to review for trends against budget and errors in classification of transactions Finance Team and Executive Directors Adjust cadence /deadlines for balance sheet reconciliations and incorporate Finance Director level review. Ensure adjustments are made in a timely manner. Finance Team Email weekly cash deposit report for Executive Directors and Finance Director to review for proper classification in the general ledger Finance Team and Executive Directors Streamline key processes which will allow finance team the time and flexibility to analyze and strategize and get ahead of firedrills; this will allow them to understand the story that the numbers are telling. Finance Team Continue to document procedures. This will ensure proper backup when team members are out due to vacation or illness. Comprehensive, documented procedures are the teams bench strength. Finance Team Ensure all transaction in the general ledger have proper backup to ensure understanding of underlying transaction Finance Team Anticipated Completion Date: End of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard and Tara Moss, Co-Executive Directors

Views of Responsible Officials and Planned Corrective Action - Our Chief Procurement Officer has been trained on entering into covered transactions and the requirement to check for any suspension or debarment by vendors in SAM.gov. The County will also maintain quotations for items over the micro-purchase threshold. This will be a documented process in the new policy and procedures manual for federal guidelines for Commission approval in November 2024. Responsible Official -Andrea Montoya, Deputy County Manager, and Robert Placencio, Finance Director Timeline and Estimated Completion Date - Resolved.

Views of Responsible Officials and Planned Corrective Action - The County has written Policy and Procedures to be reviewed by the commission in November 2024 for approval. Responsible Official -Andrea Montoya, Deputy County Manager and Robert Placencio, Finance Director Timeline and Estimated Completion Date -November 2024.

Implementation of plan of action - Management will review its procurement policies to ensure that the School complies with 2 CFR 200.320 of the Uniform Guidance. Implementation date - Anticipated completion October 15, 2024. Persons responsible for the implementation - The Board of Directors and Head of School.

Incorporate a Federal Procurement Policy (Res # 24-11)

Action taken in response to finding: 1. Review Current Procurement Policy: in progress a. Conduct a comprehensive review of Promise Healthcare’s existing procurement policy. b. Identify and revise and discrepancies or non-compliance with the requirements of the Uniform Guidance. c. Integrate industry best practices into revised policy to enhance compliance and efficiency 2. Training and Education: to start a. Provide training sessions for staff authorized to purchase along with relevant personnel on the revised procurement policy and procedures and raise awareness of the requirements of the Uniform Guidance and implications of non-compliance. b. Establish training on documentation standards for procurement activities including requisitions, solicitations, evaluations and contract awards. c. Establish training and procedure for retention of procurement-related documentation 3. Internal Controls and oversight: to start a. Implement mechanisms for monitoring and oversight to ensure compliance with the procurement policy. b. Conduct periodic internal audits to assess adherence to procurement procedures and identify areas for improvement or corrective action Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: Winter 2025

Management Comments and Corrective Action: Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related to those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization hired new procurement leadership and invested in Full Time Employees (FTEs) to develop a robust procurement department. Due to this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provide tools for selecting the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2025. Person Responsible for Corrective Action: Steven Beckman, CFO

Coronavirus State and Local Fiscal Recovery Fund – Assistance Listing No. 21.027 Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Any new vendors selected for the SLFRF program will be reviewed for suspension or debarment by the Auditor’s office in SAM.gov. Auditor’s office has discussed the process of procurement documentation of all SLFRF program vendors with administrative personnel. Name(s) of the contact person(s) responsible for corrective action: Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: November 30, 2024

Reference: 2023-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus Frederickson, Mayor; Patrick Reagan, City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2025

THE COUNCIL WILL ENSURE THAT ALL FUTURE PROCUREMENTS CORRECTLY USE AND RETAIN A PROCUREMENT SHEET WHICH DOCUMENTS THE ITEMS PURCHASED, THE BIDS RECEIVED/REQUESTED, AS WELL AS AN ANALYSIS OF THE REASONS FOR THE WINNING BID. THE WINNING CONTRACTOR/VENDOR WILL BE SEARCHED ON THE SAM WEBSITE TO DETERMINE THAT THEY ARE NOT SUSPENDED/DEBARRED.

We value your guidance and are committed to enhancing our compliance with the Uniform Guidance. In response, we will: 1. Documentation Procedures: We will implement procedures to properly document procurement activities. This will help us maintain consistency and ensure compliance with the Uniform Guidance. 2. Monitoring and Accountability: Additionally, we will establish a system to regularly monitor our compliance with these policies and procedures. This will enable us to quickly address any issues that may arise. The Finance Department will be responsible for implementing these changes and will have everything ready before the end of 2024. We are dedicated to making these improvements and truly value your support as we work through this process. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024