Corrective Action Plans

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 and 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-068-PN01, 21611-068-PN01, 20619-068-PN01, 21619-068-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Noncompliance, 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 agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Special Services will conduct the search for individuals to fill the specialized or high-need positions required. If the positions are not filled by employees of Centerville-Abington Community Schools (CACS) then a search for vendors providing the services is conducted. The Director of Special Services will obtain quotes from an adequate number of qualified sources, three if possible. The quotes will be submitted to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed quotes will be maintained in each FY grant folder. The Director will also maintain a memo of the procedure for filling the specialized or high-need positions. The memo will also be reviewed by the Superintendent of CACS each year and maintained in each FY grant folder. If a vendor is selected to fill the positions the Director of Special Services will conduct the suspension & debarment search on each vendor contracted. The suspension & debarment search documents will be printed and sent to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed suspension & debarment documents will be maintained in each FY grant folder. Copies of all of A District Accredited School Corporation Since 2007 the above described reviewed, signed & dated documents will be filed in each FY grant folder maintained by the Corporation Treasurer of CACS. Responsible Party and Timeline for Completion: The Director of Special Services will conduct the search for qualified individuals or vendors to fill the specialized or high-need positions as soon as the need is identified or as positions become open. If an individual is not hired as an employee of CACS then quotes will be obtained & a vendor will be contracted. If a vendor is contracted the Director of Special Services will conduct the suspension & debarment search within three business days of selecting the vendor. All required documents will be sent to the Superintendent within three business days of receipt of each document. The Superintendent will return reviewed, signed & dated documents to the Director within three business days. Copies will be provided to the Corporation Treasurer at the same time they are sent to the Director. These procedures will be implemented immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director (FSD) will obtain a minimum of three price or rate quotes for each vendor with expected purchases of $10,000 to $150,000 each school year. Those quotes may be from vendors within and/or outside of the purchasing cooperative. Those quotes will be sent to the Assistant Superintendent who will then present those quotes with a recommendation to the School Board at a meeting open to the public. The School Board will award the appropriate vendor with the purchase of goods for the school year. The discussion, vote and award will be noted in the minutes of the school board meeting. The Assistant Superintendent will notify the FSD of the school board?s decision via email with signed & dated quotes attached. The FSD will maintain copies of all quotes including the quotes that were not accepted in each school year folder. The FSD will send suspension & debarment documents to the Assistant Superintendent for review, signature and date within three business days of selection of the vendor. The Assistant Superintendent will return the suspension & debarment documents to the FSD within three business days of receipt of the documents. The FSD will maintain all reviewed, signed & dated documents in each school year folder. Responsible Party and Timeline for Completion: The corrective action plan will take effect immediately. All tasks will be completed before each new school year begins. The FSD is responsible to obtain three rate or price quotes. The FSD will conduct the suspension & debarment search. The FSD is responsible A District Accredited School Corporation Since 2007 to maintain the files for each school year. The FSD will send all required information to the Assistant Superintendent. The Assistant Superintendent will present and make recommendations to the School Board. The Assistant Superintendent will notify the FSD of the School Board?s decision. SUMMARY

Recommendation: We recommend that the procurement policy be updated to follow current procedures or train employees to ensure policies are followed. Action Taken: Management partially agrees with the finding. Multiple quotes were received for most expenditures. An exception, as was explained previously, were items only available from a single source. Specifically, the mailboxes at SF Suites could only be refurbished by Wolfgrass. However, management does agree that the record-keeping of those quotes was not adequate and will update procedures to address this area of concern. All purchases over $10K will receive board approval. Due Date of Completion: Immediately Responsible Official: Katie Rodriguez, Accountant and Michael Bartlett, CFO

Section III - Federal Awards Findings and Questioned Costs Compliance Requirement - Procurement, Suspension and Debarment Significant Deficiency in internal control over compliance and compliance Condition: As part of compiling the Commission's population for procurements, from which a procurement sample would be selected, the Commission identified $26,432 of expenditures charged to the grant that were erroneously included in the SEFA, as the procurement methods were not eligible for federal expenditures. As a result, prior to testing compliance related to procurement, the Commission reclassified the $26,432 of expenditures from the federal grant and removed from the SEFA as of June 30,2022. Cause: The Commission's procedures did not allow for timely identification of the expenditures prior to including on the SEFA (and claiming reimbursement). Effect: A journal entry was posted to correct current year federal revenue balance as of June 30, 2022 in the amount of $26,432. Further, the Commission has applied these expenditures to future draw downs in order to reverse the expenditures that were claimed. Recommendation: We recommend that the Commission review its closing policies and procedures as well as its federal grant management procedures to ensure procurement methods are considered prior to claiming expenditures or reporting on the SEFA. Commission Response: Staff concurs with the recommendation and has reviewed and discussed procedures with finance and transit staff. The invoices are coded for expense and funding by project managers. The reimbursement of expenditures is requested based on this information. During this time period there was a shortage of staff both in the finance and transit departments. Funding requirements were reviewed with transit staff. Finance staff will strengthen the invoice process to verify project manager coding against invoicing to prevent and if necessary, timely correct funding errors. Project Managers will be responsible for reviewing monthly project manager reports that include expenditures and associated funding reimbursed.

Corrective Action Plan for Finding IC2022-001: Financial Reporting Accomack County understands the repeat finding regarding financial reporting. In our response in FY 21 to this comment we stated ?through the addition of one FTE in the FY 23 year, staff training in particular content areas such as financial reporting, pensions and OPEB reporting, and some realignment of duties with existing staff, we are able to continue internally prepared financial reports through the year and the Annual Comprehensive Financial Report (ACFR) properly and timely?. As an update, we have not been able to make a hire at this time, and have chosen to reformat the position to non-entry level and re-advertise in the spring of 2023. While an additional resource will be helpful, existing staff understanding of timing, and year- end financial reporting will continue to be both ongoing, and a priority. Accomack County Finance continues to consider financial reporting, including the year-end annual financial report a core competency and are open to suggestions in processes or protocols that will advance our capacity and capability in this area from Brown Edwards. As part of this response, County finance recognizes we are responsible for timely and accurate reporting which includes Accomack County Public Schools (ACPS) financial information and all other component units in the ACFR. As we are currently staffed, we do not have capacity for review of ACPS financial work through the year and have previously relied on their finance department. Unfortunately, that has caused delays, findings and revisions to financial exhibits several times at year end for corrections noted by the auditors. The County will explore options for reducing the aforementioned problems and thereby improving this issue as relates the ACPS financial information. Lastly, a component of the delay in FY 22 was the Landfill Closure/Post-closure liability in conjunction with Department of Environmental Quality. We have begun a specific time-line in coordination with the Deputy Director for Public Works, who has responsibility over the landfill and south transfer station so that finance has complete and approved cost information (through the DEQ process) prior to year-end each year, or just after year-end (timely). Responsible Official: Michael T. Mason, CPA, County Administrator mmason@co.accomack.va.us (757-787-5716); estimated completion date of not later than July1, 2023 for the new hire. Corrective Action Plan for Finding FA-2022-001: Procurement Accomack County Public Schools concurs with the need to maintain its Procurement Policy in concurrence with 2 CFR Part 200. The schools will review and update procurement policies to be in compliance. Responsible Official: Chris Holland, Accomack County Public Schools Superintendent, chris.holland@accomack.k12.va.us, (757)787-5759; Estimated completion date is not later than the May, 2023 School Board meeting.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023

U.S. Department of Housing & Urban Development Cocoon House respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 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. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing & Urban Development 2022-001 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: We recommend the Agency's procurement policy is updated to reflect the current federal guidelines and that policies and procedures are implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency?s procurement policy will be updated to reflect the current federal guidelines and procedures will be implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract prices is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Name(s) of the contact person(s) responsible for corrective action: Chris Willis, CFO Planned completion date for corrective action plan: 12/12/2022

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

The Center was unaware that, in accordance with the Department of Labor (DOL)(40 USC 3141-3144, 3146, and 3147), all laborers employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for prevailing wage rates. In the future, the Center will follow the guidance of the aforementioned section and adhere to this requirement.

Item 2022-001 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits We recommend that the Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams/Amanda Myers Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation was under the assumption that the state procurement had secured the bidding/quote information for the vendor in question. Emails were given to document the ?go ahead? from our cooperative to order from the vendor. The corporation now understands that we are responsible for obtaining quotes outside of the cooperative. Anticipated Completion Date: Implemented immediately.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

Finding Number: 2022-002 Planned Corrective Action: The District is currently working with OSBA to update the policies and policy DJC states ?If feasible, all purchases over $20,000 and not otherwise subject to required federal or state bidding requirements will be based on price quotations submitted by at least three vendors.? The Treasurer and Business Manager will ensure that policy is followed when applicable. Anticipated Completion Date: October 31, 2023 Responsible Contact Person: Muata Niamke, Business Manager and Taylor Friedrich, Treasurer/CFO

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotes for vendors exceeding $10,000 from three sources. These will be reviewed and initialed by the Business Manager. For vendors with total disbursements expected to be between $50,000 and $150,000, the Food Service Director will obtain contracts from the vendors and these contracts will be stored at our Central Office. DeKalb Eastern will confirm with the Education Service Center via email or letter that the Service Center is correctly certified with the state for procurement requirements. 1f the Education Service Center remains uncertified, the Food Service Director will obtain price or rate quotes for milk from three sources. These quotes will be reviewed and initialed by the Business Manager. The Food Service Director will request a certification from vendors with contracts over $25,000 to show they are not excluded from participation in federal award programs. In the event the vendor is unable to provide a certification, DeKalb Eastern will utilize the SAM website to view the exclusions list of vendors . Anticipated Completion Date: Ongoing - The Food Service Director will obtain the necessary price and rate quotes, as well as contracts and certifications and the Business Manager will review and initial the quotes.

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate

FINDING 2022-002 Contact Person Responsible for Corrective Action: Food Service Director Billie Jo Russell Contact Phone Number: 812-755-4872 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement ? The School Corporation has established internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment requirement. The Food Service Director will obtain information from the Wilson Service Center for any necessary documentation pertaining to this requirement. The School Corporation has procured any food and supply purchases that exceed $150,000 and will maintain documentation for procurement procedures for purchases under $150,000. Suspension/Debarment ? Procedures will be implemented to ensure our procurement agent is an approved procurement agent. Anticipated Completion Date: Immediately

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INCIDENCE OF NONCOMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? ALN 10.553, 10.555, AND 10.559 2022-001 Internal Control Over Compliance and Noncompliance With Federal Procurement Requirements Finding Summary 2 CFR ? 200.320 requires management to establish and maintain effective internal control over compliance with requirements applicable to federal program procurement requirements. Independent School District No. 885 (the District) did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal procurement requirements related to the use of sealed bids and quotations. Corrective Action Plan Actions Planned ? The District will review policies and procedures relating to procurement for all federal programs to ensure that bids and/or quotations are obtained when required by the Uniform Guidance in the future. Official Responsible ? Kris Crocker, Director of Business Services. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? Kris Crocker, Director of Business Services, will assure appropriate internal controls and procedures are updated and in place to ensure compliance for future federal awards expenditures.

Views of Responsible Officials: RFE/RL Finance has provided clarification and additional guidance to Department Directors and the Procurement team to reinforce the importance of documenting the steps and decisions that result in a Sole-Source justification in the requisition process. Management has engaged Procurement consultants who have produced clear purchasing guidelines for the company including documentation requirements. RFE/RL has hired a new Procurement Director with the responsibility to improve management of the process and direction to the procurement team to ensure that support for sole source purchases is complete, maintained, and made available for review during the audit process and upon management request. Management believes that substantial progress has been made in either justifying sole source acquisitions within the limits of 2 CFR 200.320 or requiring competitive bids since the new Procurement Director has been appointed. It is Management?s intent to continue to operate in a way that removes this significant deficiency as a concern.

2022-001 Methods of Procurement Recommendation: We recommend that the County review their policies and procedures to ensure that they are operating in a manner that follows federal procurement requirements and the County?s procurement policy. The creation and use of a standard procurement checklist would assist the County in documenting all requirements for each procurement that is entered into. Management Concurs with the Finding and Recommendation Action Plan Taken in Response to Finding: The Finance Department will work with County Management and Board Departments to ensure familiarity and understanding of the County?s procurement policies and procedures. Additionally, the County is working towards the implementation of a financial system which will improve the controls in place to help ensure compliance with procurement requirements. The Finance Department is also working on a financial policies document and will would with County Manager on a review of the County?s procurement policy. Name(s) of contract person(s) responsible for corrective action: Tasha Morgan, Finance Director Planned completion date for corrective action plan: We anticipate the finding will be address by September 30, 2023

Recommendation: CLA recommends the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Dickinson County will review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Name of the contact person responsible for corrective action: Brian Bousley, Controller/Administrator Planned completion date for corrective action plan: December 31, 2023 If the State of Michigan has questions regarding this plan, please call Brian Bousley at 906-774-2573.

U.S. Department of Treasury 2022-004 COVID-19 ? Coronavirus State and Local Relief Funds (CSLRF)? Assistance Listing No. 21.027 Recommendation: The Town should review and enhance controls and procedures to ensure that it follows procurement policy for all goods and services charged to the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Town's procurement policy will be reviewed and updated to ensure compliance with federal requriements. Name(s) of the contact person(s) responsible for corrective action: Steven Repole Planned completion date for corrective action plan: 6/30/2023 If the U.S. Department of Treasury, Office of Recovery Programs has questions regarding this plan, please call Steven Repole at 410-398-4170.

CORRECTIVE ACTION PLAN Year Ended June 30, 2022 Mechanicsburg Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022. 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 2022-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster ? 10.553/10.555/10.559 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

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023