Corrective Action Plans

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

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.