Corrective Action Plans

To Whom It May Concern, As required by the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), we have provided below our response and corrective action plan addressing the finding in the Report of Independent Auditors on Compliance for the Major Federal Program and Report on Internal Control Over Compliance Required by the Uniform Guidance for the year ended September 30, 2023. Response and Corrective Action Plan Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program -Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Cause: Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Management Response: The Marjaree Mason Center (MMC) did not maintain proper records of the procurement process for two vendors associated with janitorial services and the client statistical database. MMC has formally started a new procurement policy for all vendors where the vendors will have their own procurement documents. The chosen vendors can be MMC's selected vendor from 1 - 3 years depending on the type of service. All quotes and bids will be maintained on MMC's server.

Corrective Action Planned: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget, its own existing Board Policies, and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement requirements. Effective for the 23-24 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes. The District followed appropriate procedures to ensure that procurements financed with federal funding fully comply with Uniform Guidance procurement. The District sought competitive proposals for major Middle School HVAC replacement project. The District maintains record of the process. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year. Contact Person Responsible: Cory Hoffman, Business Manager/Board Secretary

Mechanicsburg Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Greg Longwell, Director of Business Operations/CFO If there are any questions regarding this plan, please call Greg Longwell, Director of Business Operations / CFO, at 717-506-0869 or email at glongwell@mbgsd.org

Recommendation: The Auditor recommends that the procurement policy be updated to comply with all relevant federal procurement requirements and reviewed for necessary revisions regularly. Action Taken: The HEERF award should have been setup as a restricted fund. Going forward, all grants and contracts will be classified as a restricted fund and federal compliance will be followed if it is applicable. Due Date of Completion: Done Responsible Official: Stephanie Gonzales – VPFA/Comptroller and Office of Research and Sponsored Projects

Higher Education Emergency Relief Funds - Institutional Portion – Assistance Listing No. 84.425F Recommendation: Recommendation for the College to revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All contracts under consideration will go through the college’s procurement process even if there is an existing comparable contract with an existing vendor. Name(s) of the contact person(s) responsible for corrective action: Leigh FitzHenry Planned completion date for corrective action plan: 11/30/2023

The District has responded with corrective action and implemented a process in which the Facilities Director will communicate the Davis-Bacon prevailing wage requirements to the contractors of equipment purchased with federal grant funds. The Director of Business Services will verify and oversee that these requirements are met.

Broadlawns Medical Center respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF AGRICULTURE 2019-001 Special Supplemental Nutrition Program for Women, Infants and Children – CFDA No. 10.557 Recommendation; We recommend the Organization obtain quotes or bids as necessary for purchases that exceed the micro-purchase threshold. Additionally, we recommend the Organization maintain documentation of all quotes and bids to support the vendor chosen. In situations where there is an alternative method utilized, we recommend clearly documenting that process to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization adopted a procurement policy meeting the recommendations above and the requirements noted in 2 CFR Part 200 §200.318 in December 2020. The policy will be reviewed annually with staff involved in the purchasing process to ensure compliance. Additional procedures will be put in place for WIC department expenditures. Non-salary expenditures of the WIC department expected to be over $5,000 or more will be discussed with the CNO for approval prior to purchase. The Purchase Requisition form will be used to document purchasing approvals. Quotes or bids along with a written rational for vendor selection will be included with the Purchasing Requisition form. Once reviewed and approved by the CON, the Purchase Requisition, quotes/bids, and selection rationale will be sent to Director of Accounting and Cost Accountant. The Director of Accounting will timely review the documentation and forward it to the purchasing department to place the order. Both the Director of Accounting and the Cost Accountant will maintain copies of the documentation for reporting and auditing purposes. Name of the contact person responsible for corrective action: Jim Lynch Planned completion date for corrective action plan: January 31, 2024 If there are questions regarding this plan, please call Jim Lynch at 515-282-2296

We will revise our policies and procedures on purchases with federal awards so that we will meet these newly required federal procurement regulations. We will start including Appendix II to Part II Summary where applicable in future contracts.

Condition: We identified 4 expenditures, during testing, that the City did not verify were in accordance with their internal procurement policy, pursuant to 2 CFR 200.319 and 200.320 prior to entering into contracts with award funds. Planned Corrective Action: Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City of Port Huron management and staff will continue to improve communication with and between departments to ensure all staff understands the purchasing policy. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

The Business Department will review the Uniform Guidance requirements with all grant administrators and procurement staff to ensure compliance with federal regulations and district policy; and it will establish a more thorough review process for contracts to ensure compliance with all requirements.

Finding: 2023-002 – Procurement, Suspension, and Debarment – Contract Bidding Auditor Description of Condition and Effect. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Auditor Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. Corrective Action. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Person: Emili Jones, Director of Business and Finance Anticipated Completion Date: November 1, 2023

Contact Person – Lora Papacheck, CEO Planned Corrective Action – Entity management will review a list of vendors and update documentation in accordance with Procurement standards. Completion Date – Fiscal year 2024

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Rouba Anka, Chief Financial Officer Planned Completion Date: Immediately

District will review procurement policies and provide additional training and education to ensure the minimum requirements of 2 CFR 200 and the procurement policies established are being followed.

There is no disagreement with the finding. Management has updated their district policy and continues to work with staff members to ensure proper execution of purchases.

The District updated the District’s policy and is in the process of providing training to those affected.

Landesa will revise it’s Procurement Policy to meet the standards of the United States Federal Government and all components of 2 CFR Section 200.320. Landesa will revise the Procurement Policy to include clear thresholds for small purchases and simplified acquisitions and clearly address the topics of sealed bids, price analysis, and acquisition costs. Landesa will revise existing procurement forms, such as the third-party due diligence form, to ensure compliance with the revised policy. Landesa will provide training to all relevant staff on the revisions to the Procurement Policy by March 2024. The Director of Program Effectiveness will monitor staff implementation of the revised policy and procedures to ensure compliance with revised policy. Contact person: Director of Program Effectiveness and Anticipated completion date: March 2024

Finding, #2023-001 and #2023-002· Material Weakness - Other Matters, Government Auditing Standards; Major Federal Award Finding - Procurement and Suspension and Debarment Corrective Action Plan: We recognize the carry over nature of these findings in that the contract with the vendor that triggered the finding began in fiscal year 2022 and the work was not completed until fiscal year 2023. Revise the current procurement policy to include federal regulations 2 CFR Section 200.317-200-326 per the thresholds in CFR 200.320. The revised policy will be reviewed with managers responsible for procurement that could potentially exceed these thresholds. Our procurement procedure will be revised to clearly specify the requirements for Small Purchase Procedures for purchases between the micro-purchase threshold and the simplified acquisition threshold per federal government regulations.

Dover Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2023-001 – Procurement Federal Agency: Department of Education Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: COVID-19 – Education Stabilization Fund – 84.425 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Miranda Weaver, Chief Financial & Operations Officer

Finding number: 2023-003; Finding: While testing the procurement requirement, we were able to test compensating controls, but noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: UW Health will develop processes and procedures to ensure compliance with the Uniform Guidance. Vendors will be reevaluated for compliance with the Uniform Guidance prior to being charged to any grant. Anticipated completion Date: June 2024; UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services, and Sara Schiek, Manager of Procurement Services

Management agrees with the findings presented by the auditors. Management has taken the following actions already to meet this standard. The Organization has taken corrective actions to meet this standard for FY24. These actions include the drafting of a procurement policy that aligns with the requirements outlined in 2 CFR 200.320 and communicating the policy to its staff for use when planning to allocate procurement costs to federal grants. Management plans to leverage the existing system in place to track and document compliance with the standard procurement procedures as outlined in the policy. Management is committed to conducting periodic internal reviews as part of our compliance checks. We are dedicated to maintaining strong internal controls over compliance, and these measures will help us meet the standards for procurement used in the acquisition of property or services required under Federal awards.

Condition: The District did not follow the small purchase method for procurement that is required for purchases made between $10,000 and $250,000. This method requires that price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b). Recommendation: We recommend that care is taken to ensure that all the procurement requirements are followed based on the amount of the purchase being made with the federal funds. Management Response: We will follow the procurement standard when not in urgent situations for the product or service we are seeking. Anticipated Date of Completion: June 30, 2024

219 Health Network will develop a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.

Contact Person – Aimee Sugden, County Administrator Corrective Action Plan – The County will review policies and procedures over uniform guidance procurement. Completion Date – January 1, 2026

Contact Person – Aimee Sugden, County Administrator Corrective Action Plan – The County will review policies and procedures over uniform guidance procurement. Completion Date – January 1, 2026