Corrective Action Plans

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jennifer Farley Contact Phone Number: 765-292-2626 View of Responsible Official: I concur with the finding. COVID -19 Procurement and suspension and debarment: 1. I was unaware of these requirements at the time the money was spent. In the future I will make sure this is done correctly. Anticipated Completion Date: Done

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Amanda Bilbrey, Food Service Assistant Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Food Service will review bid packets to ensure documentation was provided as proof that the vendors were not suspended or debarred. If such evidence is not provided, the Food Service Director will verify and request appropriate documentation. Anticipated Completion Date: March 24, 2023

Finding No. 2022-002 Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy. Timing of Completion This corrective action has been implemented in FY23. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Brian Seabold, Director of Procurement (201) 216-8722.

Finding Number: 2022-002 Planned Corrective Action: See Below Anticipated Completion Date: 01/05/2023 Responsible Contact Person: Brian Haines, Treasurer 1. The Treasurer will educate all responsible parties (Director of Curriculum, Assistant Superintendent, Accounts Payable, Superintendent) in the District regarding to Federal Procurement requirements. 2. The Treasurer will ensure that all requests follow the Districts Purchasing Procedures, as well as the Federal Procurement Requirements.

Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Management agrees with the finding related to Procurement, Suspension and Debarment. To address these deficiencies Research Operations will conduct staff training for Departmental Research Administrators to ensure staff are knowledgeable of the current policy and the documentation requirements related to purchases above the micro-purchase threshold. D-H is currently following the required procedures but will ensure that the procurement files include supporting documentation, including review of multiple vendor quotations or sole source justification documentation. Furthermore, D-H will update procedures to ensure that all purchases have evidence of the suspension and debarment verification completed prior to payment. Leadership Responsible: Barbara A. Vance, PhD, CRA, Vice President, Research Operations Anticipated Completion Date: 12/31/2023

FINDING:2022-003 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: In the future the Food Service Director will check on Sam.gov for any Disbarment on any purchases that is over $10,000.00. She will print it out and initial and keep on file. In the future the Food Service Director will include in their Service Agreement form #1048, for Disbarment, Suspension. The School Corporation will seek Bids/Quotes for anything over $10,00.00 in the future. If the school is not asking for Bids/Quotes for repairs, we will use the company that we have a Maintenance Agreement with. Anticipated Completion Date: February 2023

The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will anticipate annual procurement expenses with vendors outside of the Southern Indiana Education Center, If the anticipated expenses for the fiscal year are in excess of $10,000 but less than $150,000, the food service director will work to obtain quotes from at least three sources. If the anticipated expenses for the time period are in excess of $150,000, the food service director will conduct a formal bid process and award a contract to the most qualified, lowestpriced vendor. Any vendor with a contract for purchases of $25,000 or more will need to provide a certification or include a contract clause stating the vendor is not suspended or disbarred from participation in federal assistance programs. If not certification or contract clause is produced, the food service director will contact the corporation treasurer to check the vendor's status in SAM. Anticipated Completion Date: August, 2023

CORRECTIVE ACTION PLAN FINDING 2022-004 Contact Person Responsible for Corrective Action: Region 8/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

U.S. Department of Education 2022-001 Education Stabilization Fund- Procurement, Suspension & Debarment Assistance Listing No. 84.425F Recommendation: We recommend the College establish policies and procedures to properly identify procured transactions and maintain documentation to support performance of the procurement procedures. We also recommend the College evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training related to federal spending guidelines will be given to any staff or faculty who are responsible for spending new federal money. Name(s) of the contact person(s) responsible for corrective action: Teri Simmons Planned completion date for corrective action plan: April 2023

Re: Finding 2022-001: GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received.

DEPARTMENT OF TREASURY AND CENTERS FOR DISEASE CONTROL AND PREVENTION 2022-004 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ? Assistance Listing No. 21.027 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ? Assistance Listing No. 93.323 Recommendation: We recommend the County design controls to ensure compliance with federal procurement and suspension and debarment regulation and its purchasing policy and suspension and debarment verification procedures. We recommend the County develop standard justification forms with approval of the noncompetitive procurement documented on the forms and the forms maintained in the procurement file. Also, we recommend the County update its purchasing policy to ensure clear, concise, and detailed suspension and debarment verification procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The County is currently in the process of implementing 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. Name(s) of the contact person(s) responsible for corrective action: Desiree Belding Planned completion date for corrective action plan: November 30, 2023

The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with 200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors. CFO, Eddriene Sylvester. Timeline 180 days.

District Response: A. What corrective action will be taken: District will follow all the requirements of 2 CFR 200 with respect to federal procurement requirements. B. Who is responsible (name and position): Dr. Stephen Gregory, Federal Program Director C. When will the plan be implemented? Corrective action started May 5, 2023, and will continue.

The Fiscal Officer and management company have reviewed the description of the issues and are taking steps to put stronger documentation procedures in place that will support the evaluation and selection of vendors paid from Federal programs. With respect to these specific purchases in FY22, we are confident that if the process had been appropriately documented, we would have reached similar conclusions about who was ultimately selected as the vendor for these projects. We believe the corrective actions we are taking will put us in full compliance with 2 CFR part 200 and the School?s Federal Procurement Policy in future periods.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Bryce Welsh Contact Phone Number:765-345-5101 Views of Responsible Official: We concur with the finding. While we believe that we had controls in place for this finding we failed to produce the proper documentation to prove that we did so. Description of Corrective Action Plan: Going forward we will make sure that all suspension and debarment documents are provided to the Business Manager and kept at central office. These documents will be reviewed and signed by the Business Manger showing internal controls are in place. We will also ensure that we have a contract with the vendors for purchases between $50,000 and $100,000. Anticipated Completion Date: 3/14/2023

There is no disagreement with the finding. The District will review and update their procurement policy to ensure compliance with Uniform Guidance. The District management will also communicate with appropriate staff members to ensure compliance with District policy. District contact for corrective action plan: Brian Walters, Business Manager 920-565-4454 ext. 313 Anticipated Completion Date: Finding 2022-003 will be addressed immediately and corrected during the 2022-23 fiscal year.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jami Parks Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The School Corporation will sign agreements with Food2School for all Food Service contracts to obtain quotes, these quotes will meet Procurement, Micro purchases and simplified acquisition requirements. Food2Schools will also obtain and share documentation with the school showing vendors meet suspension and disbarment requirements. Anticipated Completion Date: August 01, 2023 (Beginning of the 23/24 school years)

Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement standards. View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Federal acquisition thresholds and requirements. Effective the 22-23 fiscal year forward the District will fully deploy the referenced administrative procedures to all applicable District stakeholders and monitor all such procurements for compliance purposes.

Views of Responsible Officials and Planned Corrective Action ? The Purchasing Director will update policies and procedures to specifically address procurement for federal awards. The University will also ensure that Purchasing Department and Business Office staff participate in annual federal compliance training. Timeline and Estimated Completion Date: December 2022 Responsible Party: Aaron Flure, Purchasing Director and Stephanie Gonzales, Comptroller

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Jake Roger, Town Administrator. Corrective Action Plan: The Town will produce policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Completion Date: December 31, 2023.

FINDING: 2022-002 Contact Person Responsible for Corrective Action: Deborah A. Longer, Clerk-Treasurer Contact Phone Number: (219) 942-1940 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The special purchase procurement of the CNG refuse haulers was done by Resolution of the Board of Public Works and Safety. This Resolution included references to the State Statutes permitting acquisitions of this type but did not include any reference to the Federal statutes and requirements. In addition, the Employee in Responsible Charge (ERC) and the agency assisting with the grants and purchasing failed to verify that the vendor was neither suspended nor debarred to assure they would be a qualified vendor. The City Attorney has been appraised of both of these issues. In the future, any special purchase of equipment that utilizes Federal funding will include a reference to the State and Federal statutes governing such in the City?s official action prior to moving forward and will meet all of the requirements of same. In addition, the City Attorney has included in all City contracts that the Vendor is required to provide assurances that they are a qualified vendor and not currently suspended or disbarred from doing business. In addition, each ERC will be provided a copy of the Finding 2022-02 to serve as a reminder of their responsibilities and the necessary procedures and activities related to the overseeing of the grants and direct them to review the Internal Control Policies regarding the responsibilities, procedures and activities to assure the proper reporting in all areas of the SEFA in future years. Anticipated Completion Date: April 30, 2023 Signed: Deborah A. Longer Deborah A. Longer, Clerk-Treasurer Date: April 19, 2023

U.S. Department of Housing and Urban Development Lake Wales Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-001 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority update it Procurement Policy from 2009, which was done on September 30, 2022, putting in place the procurements listed in the Uniform Guidance (UG) and clarifying procurement methods. As well as, including in the policy that all vendors? eligibility needs to be verified prior to signing contracts, either through the SAM website or by collecting a certification form from the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The new procurement policy was approved September 20, 2022 Name of the contact person responsible for corrective action: Al Kirkland, Executive Director Planned completion date for corrective action plan: Completed September 20, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Al Kirkland, Executive Director at (863)676-7414 ext. 12.

The District understands the need to properly document procurement efforts in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their procurement efforts for federal and state grants.

There is no disagreement with the finding. District will follow their Procurement policy for small purchases and proposals by obtaining price quotes from a minimum of two vendors and maintain documentation.