Corrective Action Plans

The School District has already made the request and received letter from ODE for the FY `23 audit period.

Finding 2022-003 The School District did not provide evidence that it was in compliance with formal procurement methods. The School District will make every attempt, when possible, to remain in compliance with formal procurement methods. School Business Administrator and Superintendent of Schools 2022-2023 fiscal year

Kittitas Reclamation District P.O. Box 276 Ellensburg, WA 98926 Phone: (509) 925-6158 Fax: (509) 925-7425 CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kittitas Reclamation District January 1, 2022 through December 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District?s internal Controls were inadequate for ensuring it complied with federal procurement requirements. Name, address, and telephone of District contact person: Stacy Berg PO Box 276 Ellensburg, WA 98926 (509)925-6158 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Upon receiving the guidance on the current audit, the District would like to move forward by reviewing the procurement policy and making any necessary changes while working under the guidance of the SAO Procurement Specialist to ensure that an updated procurement policy continues to meet the needs of the District and the federal guidelines for federal funding. Anticipated date to complete the corrective action: September 30, 2023

Finding # 2022.001 Procurement and Suspension and Debarment Response Management acknowledges the condition related to following the organization?s procurement policy guidelines. Management is taking steps to correct this condition and has identified areas in the system that will be corrected in order to follow all Federal requirements related to procurement. For example, a member of the Finance department will complete procurement training at least once a year. The Finance Department will also train all Project Managers in Procurement Policies and Procedures as needed. Responsible Party David Ayala, CFO Estimated Completion 12/31/2023

The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.

Finding No. 2022-001: Procurement and Suspension and Debarment ? Significant Deficiency (Program Level) Finding: During testing the Federation?s controls on compliance over procurement and suspension and debarment, the Federation could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Corrective Actions Taken or Planned: Management will update its procurement policy to ensure it is in compliance with Uniform Guidance requirements and will take the additional steps of updating the policy as changes in the Uniform Guidance requirements occur. Review and monitoring is effective immediately and will be on-going beginning January 2023 and is expected to be completed by February 2023

The responsible officials within the Foundation acknowledge the findings from the 2022 audit related to our procurement practices under 2 CFR section 200.320. We understand the gravity of the situation, particularly considering that the Foundation did not have a formal procurement policy in place. To address the deficiencies identified in the audit, our planned corrective actions are foundational. Firstly, we will develop and implement a comprehensive procurement policy that adheres to the federal regulations specified in 2 CFR sections 200.318 through 200.326. This policy will provide clear and specific guidance on both competitive and noncompetitive procurement methods, establishing a framework for future procurement activities. Secondly, we recognize the paramount importance of robust documentation. Therefore, we will institute rigorous documentation procedures that mandate the thorough recording of the historical context and rationale for procurement decisions at the time of contract execution. This documentation will be meticulously maintained, adhering to the stringent requirements mandated by the federal regulations. Additionally, we will prioritize staff training to ensure that all personnel involved in the procurement process are well-informed about the new policy and are capable of consistently adhering to the documentation standards. These measures, including the creation of a procurement policy from the ground up, will enable us to rectify the audit findings promptly, establish compliance with federal regulations, and uphold the integrity of our federal award programs.

Significant Deficiency in Internal Controls ? Procurement, Suspension and Debarment Funding Agency: Department of Treasury Program: Emergency Rental Assistance Program Assistance Listing Number: 21.027 Criteria or Specific Requirement: Criteria or specific requirement: 2 CFR 200.318(i) states that "the non-Federal entity must maintain record 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, 2 CFR 200.320(a)(2)(i) states that "... If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity". Per the Organization's written procurement policy, the adequate number of sources is determined to be three. Condition: For the entire population (two disbursements from one procurement), documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required and stated in the Organization's written procurement policy. Context: A sample of two disbursements from a population of one procurement transaction charged to the major program that exceeded the Organization's established micropurchase threshold of $10,000. The transaction was found to be out of compliance with the Procurement requirements, as documentation was not retained for the adequate number of price comparisons. Questioned Costs: Undeterminable Cause/Effect:. An employee charged with the procurement process for these transactions misinterpreted the aggregation rules between capitalization and procurement thresholds, and therefore did not obtain nor retain three contemporaneous quotes. Without adequate records retained, the Organization is at risk of noncompliance with the standards of Procurement. Recommendation: Opportunity Council has already taken steps to communicate the error with the applicable employee and is currently implementing an additional level of fiscal review earlier in the procurement process to ensure that documentation exists prior to procurement and that it is retained with the accounting record. We recommend moving forward with the additional layer of review and emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Organization. View of Responsible Official and Corrective Action Management accepts the finding and is taking the following corrective action to prevent recurrence: ? Updating Organizational Policies to clearly permit a higher small purchases threshold, combined with annual certification of eligibility, to sharply decrease the likelihood of recurrence of the underlying cause of the finding. ? Implementing accounting system-level controls that will require an additional approval from assigned fiscal staff to transactions exceeding the small purchase threshold prior to payment, ensuring accountability for monitoring of required documentation for procurements in excess of the threshold. ? Procurement training planned throughout the agency to ensure that personnel authorized to initiate procurement transactions are aware of organizational policies and have the guidance necessary to comply with procurement rules.

Finding 2022-012 ? Procurement (Significant Deficiency and Noncompliance) (Repeat finding) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.320 establishes the methods of procurement to be followed for non-federal entities when acquiring goods and services with federal awards. Aggregate purchases higher than the micro-purchase threshold must use the small purchase procedures which require price quotes be obtained from an adequate number of qualified sources. Condition: We selected a sample of six vendors to test for proper procurement procedures. Of those six, one vendor was not properly procured. Management?s View: Management was made aware of this during the end of the prior year audit. These purchases had already been made by that time. Management has implemented a corrective action plan to ensure that policies and procedures are followed. Corrective Action Plan: Management has informed department heads regarding the need to obtain multiple quotes for purchases higher than the micro-purchase threshold and below the bid threshold. Management is in process of updating Policies and Procedures to include this requirement for Procurement. Going forward, requisitions submitted requiring multiple quotes will not be approved without a minimum of three (3) quotes provided by the requester. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023

Finding Number: 2022-005 Condition: The Corporation's procurement procedures does not fully conform to the procurement standards identified in ?? 200.317 through 200.327. Planned Corrective Action: The procurement policies will be revised and additional education will be conducted for those individuals responsible for the procurement process. Contact person responsible for corrective action: Kristen St. Peter Anticipated Completion Date: June 2023 Management Response: Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.

INTERNAL CONTROL ? MATERIAL WEAKNESS AND NONCOMPLIANCE 2022-003 ? Procurement Contact Person: Finance Director Date for completion: December 2023 Recommendation: We recommend that the City adopt a proper procurement policy that is in line with Uniform Guidance. We further recommend that the City develops a centralized procurement process whereby appropriate procurement type is documented along with the maintenance of proper pre-award documentation. Views of Responsible Officials and Planned Corrective Actions: The City will work internally within the City Manager?s office and Finance Department to adopt a centralized procurement process and policy that is in line with Uniform Guidance. Staff identified to participate in the process will be trained as needed.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Christy Nale Contact Phone Number: 765-492-5411 View of Responsible Official: Procurement request for milk and dairy was requested from the West Central Educational Service Center. After not receiving the bid request in a timely manner, the procurement bid was received from the Wilson Education Center. The North Vermillion Community School Corporation was unaware that the Wilson Education Center was not IDOE approved in 2021. The IDOE approved cooperative list was not made available to our corporation, and not easily accessible on the IDOE School Nutrition link. Description of Corrective Action Plan: The corrective action has been made as the Wilson Education Center was approved as a Cooperative Procurement site in 2022 by the IDOE. Anticipated Completion Date: No anticipated date, the Corrective Action has already been completed.

Finding 2022-003 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: Frontier School Corporation will have the Food Service Director prepare contacts to all possible food & drink vendors asking for Vendor Bids for the following school year. Any email correspondence will be CC?d to the Corporation Treasurer and Superintendent when contacting the Vendors. A phone call log will also be kept by the Food Service Director. After receiving Vendor Bids, all Vendor Bids or Vendor Declining to Bid will be presented to the School Board for their approval. The Food Service Director will also give a recommendation at that time on who they would like to award the Vendor Bid to. After the School Board vote on Vendor Bid Awards, e-mail correspondence will be sent to all vendors with Corporation Secretary and Superintendent CC?d. All email data, phone logs, and School Board notes will be filed in the Food Service Director?s office. This internal control system will ensure compliance with the state Procurement agreements and requirements. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. Suspension and Debarment: Frontier School Corporation Food Service Director will check SAM Exclusions, collect a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. This information would then be kept in the Vendor?s file. Anticipated Completion Date: The CAP will be in place by March 17, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. The Food Service Director will have current vendors checked on SAM Exclusion or have a certification from that vendor, or adding a clause or condition to the covered transactions with the current vendors by March, 17, 2023.

U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement and Conflict of Interest Policies were recently revised in Oct 2022 and Dec 2022 ahead of HRSA operational site visit to meet Uniform Guidance requirements. Staff have been trained on requirements related to the procurement thresholds and documentation standards. Documentation and discussion of procurement standards will be captured per that policy, with board action and discussion. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022

Finding Number: 2022-03 Anticipated Completion Date: 10/31/2022 Responsible Contact Person: Laurence Emrie Planned Corrective Action: In response to PwC?s prior audit finding, the Company completely revised its Vendor Selection Form (for Projects Expending Federal Funds Only), effective as of October 2022, to provide explicit directions on the process to be followed when requests for bids from multiple vendors result in only one responsive bid being received. As such, this issue was remediated in October 2022. In such cases, the procurement must be documented as a noncompetitive procurement in Section 3 of the Vendor Selection Form. As a result, enhanced documentation must be attached to the Vendor Selection Form to justify the use of noncompetitive procurement as a purchase mechanism before the purchase will be approved. Moreover, management oversight of the procurement process has been enhanced by having both the Legal Office and the Accounting/Finance Office review and sign-off on the Vendor Selection Form and supporting documentation prior to purchase authorization for goods or services above the micro-purchase threshold being approved.

CORRECTIVE ACTION PLAN Pursuant to Federal Regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in County of Jackson, Michigan?s Single Audit report for the year ended December 31, 2022, and corrective actions to be completed. 2022-001 ? Procurement, Suspension and Debarment Auditor Description of Condition and Effect. The County charged costs for multiple vendors to federal grants that they determined fell under noncompetitive procurement in accordance with 2 CFR 200.320. However, documentation was not obtained to support such determinations. As a result of this condition, several vendors paid with federal funding appeared to be procured in a manner not in accordance with federal regulations. Auditor Recommendation. We recommend that the County implement a policy to address noncompetitive procurement circumstances. Corrective Action. The County agrees that a policy needs to be implemented to address noncompetitive procurement circumstances. Responsible Person: Cecilia Anderson, Finance Director Anticipated Completion Date: December 31, 2023

Price or rate quotes will be obtained from three different sources when required by the Uniform Guidance. Doris Guzman will monitor budget projections to determine which expenses will require implementation of the appropriate level of procurement procedures that must be followed. Additionally, Hispanic Federation?s program managers will be trained on how to execute the Hispanic Federation Procurement Policy. Finally, Hispanic Federation?s new Compliance Department will review contracts to determine compliance needs.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number: (812) 438-2655 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will maintain communication with the Wilson Education Center to ensure that they comply with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. In the event that the Wilson Education Center does not comply with the above requirement, the school corporation will look at the federal website to ensure that all vendors are on the approved list. If the Wilson Education Center fails to meet the above criteria, the school corporation would advertise to solicit bids for milk and bread. Anticipated Completion Date: January 13, 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Judy Brooks, Food Service Coordinator Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Coordinator will follow our procurement procedures for all purchases. Food Service Coordinator will document that vendors for the BID are not suspended or debarred from participation in federal programs before purchasing also vendors used through the Wilson Center. The Deputy Treasurer will verify procurement and suspension and debarment documentation is on file before payment is made. When we are checking the vendors on the sams.gov website and there are no results founds then we will also request the vendor to submit a suspended and debarred form. Anticipated Completion Date: 2/13/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. It is the responsibility of the Food Service Director to ensure compliance and comply with the grant agreement and the Procurement and Debarment compliance requirements. Each School year, the Food Service Director & Superintendent will present the West Central IN ESC Food Service Bids & any Food Service Small Purchase quotes to the School Board for review and approval. Audit Evidence will be the Board packets and Board Minutes. Food Service Small Purchases- The Food Service Director will obtain quotes directly from the vendors or use the vendor?s website/catalog to compare products and prices. The Food Service Director attends WCIESC procurement meetings to get the most up-to-date pricing information. It is the responsibility of the Food Service Director to keep all documentation. The Food Service Director will present the documentation to the Business Manager for review. Small Purchase Vendors will be approved by the School board each School Year. Audit Evidence will be the quote documentation as well as the Board packets and Board Minutes. Anticipated Completion Date: March 15, 2023

FINDING 2022-006 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. The Special Education Director will obtain pricing when cumulative costs are projected to exceed the micro purchase threshold an adequate number of qualified sources. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Anticipated Completion Date: July 31, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Thomas Gordon, Beverly Hindes Contact Phone Number: 219-996-4771 x107 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director and Superintendent will collect sealed bids or competitive proposals, as required. Furthermore, vendors will be verified with SAM for any disqualifications from participating in federal assistance programs. Anticipated Completion Date: January 2023

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Context: During testing of procurement over the Special Education Cluster, it was noted that the School Corporation did obtain an appropriate number of bids relating to Special Education consultants as required under small purchase procurement guidelines. There were two consultants charged to the Special Education Cluster during the audit period with expenses totaling $147,319. One of these consultants was selected during testing for procurement. The issue impacted both ALN 84.027 and 84.173. No issues were identified when testing suspension and debarment requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Due to the number of students we service with special needs, we often need to contract out for some of our Speech Language Pathology services. We currently have three contractors that provide outstanding services for us and we haven?t annually bid this out since the pool of providers is very small. In the future, we will document the process that we take to try to fill these spots with full time employees, how we request various pathologists from a multitude of vendors, and the decision making process to choose the contractor. We will review the rates provided by other potential contractors and seek School Board approval for whomever is the contracted vendor. Responsible party and timeline for completion: Our Director of Student Services, Rebecca Gromala, will oversee this corrective action plan. It is too late to make this correction for the current 2022-2023 school year. We anticipate this being corrected by September 1, 2023 for the 2023-2024 school year.

The management team agrees with the auditor?s recommendation and has already implemented controls to address the stated concerns. Due to the public health emergency related to COVID-19, management elected to use the exception under 2 CFR 200.320(c)(3) due to the public exigency or emergency. However, management understands that the related compliance requirements have since been updated and we have adopted procedures to review any updates to compliance requirements prior to executing contracts with federal awards. Additionally, the Grants division has attended multiple trainings since the occurrence pertaining to SLFRF compliance requirements. The Grants Director also subscribes to several listserv notices to keep current on any changes in guidance. The Grants Director is responsible for the corrective action as it relates to this finding.

2022 ? 006 (Previously 2021-012) Procurement (Significant Deficiency and Noncompliance) Management?s Progress for Repeat Findings: The City plans to review the controls in place to ensure that our federal procurement guidelines are clear on City process and the need for retention of proper supporting documentation. In addition, we will also plan to have the SEFA completed well before the deadline to allow sufficient management review and major programs can be identified earlier in the audit process. The additional time will allow City departments to provide requested audit documentation within the Auditor?s deadlines. Management Response: The City respectfully disagrees with the finding. The two exceptions noted above are, on the contrary, examples of good fiscal management by the City. The statewide price agreement and the cooperative education services contract were both competitive. The uniform grant guidance in to ? 200.318(e) below encourages state and local intergovernmental agreements. To foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. In addition, the City did compete the temporary employment services. The request for bids awarded contracts in October 2016. Three (3) years, three (3) months into the five (5) year term of the contract, the first COVID case was reported in the United States and the President declared a public health emergency on January 31. New Mexico and the City of Albuquerque soon followed with their declarations. The City made the decision to extend the existing contract with the existing rates. There is nothing in City policy that prevents extension of contracts for a specific length of time. Extending the contract most likely was a cost savings to the City because the rates would most likely would have increased. Auditor?s Response: We were not provided supporting documentation, as identified in management?s response, during our testwork over procurement to apply the necessary procedures to resolve this exception. Timeline and Responsible Position: June 2023 ? Chief Procurement Officer