Corrective Action Plans

Finding 2022-002 ? Child Nutrition Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: (765) 226-0603 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have joined the Food 2 School consortium beginning with 2022-2023 school year. Both our Food Service Director and our Business Manager receive all emails and communication. This will allow internal control and oversight to ensure that the consortium is compliment with all state and federal procedures. We also have moved all of our small purchases into this purchasing consortium system. Anticipated Completion Date: August 1, 2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

Finding Number: 2022-002 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: March 31, 2023 Planned Corrective Action: The School has shown improvement in taking the required action and is aware of the need to verify that vendors are not debarred; however, the manner of keeping records, of such action, is still lacking. The importance of such record keeping has been stressed to the new person responsible for the accounts payable activity of the School.

2022-004: Procurement (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority implemented a procurement policy effective January 2022. Completion Date ? January 2022 Contact Person ? Jami Blosmo, Accounting Manager

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

Finding 2022-004 Contact Person: Teri Langwell, Chief Financial Officer Anticipated Completion Date: 12/1/2022 Corrective Action Plan: The College will review the procurement manual and update to ensure compliance.

2022-003 - Procurement 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 methods. Effective for the 22-23 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. 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: Kenneth L. Medina, MBA, Business Manager/Board Secretary

DHS agrees with the finding and recommendation. DHS will remind staff via electronic memoranda to ensure compliance with federal and County procurement requirements and maintain records sufficient to detail the history of the procurement.

2022-003 ? Procurement, Suspension, and Debarment Corrective action plan: The Tribe will amend its Financial Management System, to increase the micro-purchase procurement threshold from $2,000 to $10,000, set by the Federal Acquisition Regulation. When processing Purchase Orders, the Purchasing Clerk will verify that a minimum of three bids or quotes have been submitted with the Purchase Order request, for those items costing $10,000 or more. This requirement will help ensure that goods and services are being obtained at a fair price. The Tribe will amend its Financial Management System to include a policy on suspension and debarment. For purchases exceeding $25,000, the Finance Manager will perform a search of the vendor on the Systems for Award Management (SAM) website, to verify that the vendor receiving payment has not been suspended or debarred. Personnel responsible for corrective action: Finance Manager (Lisa Donham) Estimated corrective action completion date: December 31, 2023

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number: 317-485-3100 Views of Responsible Official : We concur with the finding Description of Corrective Action Plan: The Food Service Director (FSD), with assistance from the CFO, will develop a plan to secure a third vendor for kitchen equipment repairs, both for emergencies or regular maintenance repairs. The FSD and CFO will also develop a plan to solicit service plan proposals from qualified providers. The FSD and CFO will utilize approved service agreements through purchasing cooperatives, if available or, solicit responses through the public works bidding process. If a responsive responsible bidder can be secured, the service contract will be approved by the school board of trustees. Anticipated Completion Date: 7/1/2023

Finding 2022-002 ? Procurement in Compliance with Uniform Guidance Corrective Action Plan The County will adopt a procurement policy in compliance with the requirements of the Uniform Guidance. Person(s) Responsible: Chet Esther, County Board Chairman Timing for Implementation: November 30, 2022

Finding Number: 2022-003 Planned Corrective Action: The district will put procedures in place to ensure that all future purchases with federal funds follow the board policy for federal procurement. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Sandi Hurd, Treasurer

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds. Person Responsible: Grant Principal Investigator, Assistant VP of Office of Sponsored Projects and Manager of Office of Sponsored Projects. Targeted Correction Date: June 30, 2023.

Finding Number: 2022-002 Planned Corrective Action: The district will improve internal controls to ensure that all contracts utilizing federal funds will adhere to both state and federal procurement guidelines as well as the School District?s procurement guidelines. Anticipated Completion Date: 6/1/2023 Responsible Contact Person: Adam Quirk, Treasurer

2022-004 INTERNAL CONTROL OVER COMPLIANCE AND COMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT The National Trust has a Procurement SOP that is fully responsive to CFR ?200.318, and the sampled expense complied with that policy when procured in April 2022. Federal funds were awarded in July 2022 permitting reimbursement of costs incurred as early as March 2021. At the direction of pass-through entity Westchester County, these one-time coronavirus relief funds were applied to reimburse the National Trust for expenses selected by that entity even though the vendors were contracted prior to the award of relief funds. To remedy any gaps in our process, the National Trust will modify the Procurement SOP to clarify that multiple contracts with a single vendor must be treated as a single contract for purposes of the small purchase threshold and will ensure that all expenses are subject to the more stringent requirements under CFR ?200.318. Additionally, the National Trust will modify the procurement procedures to ensure that suspension and debarment screening occurs prior to entering contracts. Individual(s) Responsible for Corrective Action Plan: Thompson Mayes Chief Legal Officer and General Counsel 202-588-6182 Anticipated Completion Date: June 30, 2023

Finding 2022-003 ? Procurement in Compliance with Uniform Guidance Corrective Action Plan The County will adopt a procurement policy in compliance with the requirements of the Uniform Guidance. Person(s) Responsible: Jeff Voigt, County Board Chairman Timing for Implementation: November 30, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number: (765) 675-2147 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Superintendent and Treasurer will work to ensure that bids are sought and kept on file for projects exceeding the simplified acquisition threshold. Once a vendor is selected, Treasurer will search exclusions in the Sam.gov portal for vendors that may be suspended or debarred from participation in federal assistance programs and keep said documentation on file. Anticipated Completion Date: Immediately.

U.S. Department of Transportation 2022-001 Formula Grants for Rural Areas ? Assistance Listing No. 20.509 Recommendation: We recommend that current policies and procedures over covered transactions be updated to include one of the following procedures related to suspension and debarment: - Searching for the person or entity within the Excluded Parties List System; - Collecting certification from the person or entity; or - Adding a clause or condition to the covered transaction with that person or entity Additionally, all contracts should be maintained and kept on file to ensure records are complete. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VAC management has drafted a policy to ensure that a check of the excluded parties list system is completed and documented prior to entering any covered transaction over $25,000. Name(s) of the contact person(s) responsible for corrective action: Justin Dooley, Finance Director Planned completion date for corrective action plan: 2/15/2023

Oak Park Elementary School District 97 06-016-0970-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022 - 004 Condition: The District procured $125,877 in goods from a vendor and did not comply with their internal procurement policy. Plan: The Senior Director of Finance will work with the Food Service Coordinator to review vendor contracts and solicit bids from multiple vendors to ensure compliance with the District?s internal procurement policy and federal requirements. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Patrick King, Senior Director of Finance

Planned Corrective Action: The contract with Prodigy- Building Solutions LLC is in its final stage for completion at this point, Going forward the district will request more documentation from the Ohio Purchasing Council before awarding a future project. Anticipated Completion Date: November 1, 2023 Responsible Contact Person: Ben Teeters, Treasurer, Hillsboro City School District

FINDING 2022-003 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: The Director of Food Service and Assistant Director of Food Service will review the SAM Exclusions prior to entering a financial agreement with the vendor. The Child Nutrition Secretary will review all claims to ensure no contractors are subject to non-procurement debarment suspension are used. The acquisition threshold will be monitored for all vendors by the Director of Food Service and Assistant Director. Formal bid process and awarding of contracts will be followed as federal regulations required. ANTICIPATED COMPLETION DATE: March 2023

FA 2022-001 Improve Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States COVID-19 - 84.027 Special Education Grants to States 84.173 - Special Education Preschool Grants COVID-19 - 84.173 Special Education Preschool Grants Federal Award Number: H027A200073 (Year:2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022) Questioner Costs: $72,747 Description: A review of expenditures charged to the Special Education Cluster (Assistance Listing Numbers 84.027 and 84.173) revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: We concur with this finding. Internal Controls procedures have been reviewed and will be followed to ensure that required procurement methods are being applied to each transaction and that proper documentation is maintained in the expenditure field. Transactions will be reviewed by the Program Directors to ensure that the internal control procedures are operating appropriately and in accordance with Federal Programs Uniform Guidance. Estimated Completion Date: Fiscal Year 2023 Contact Person: Trey Wood, Finance Director Telephone: 706-795-2191 ext. 1023 Email: trey.wood@madison.k12.ga.us

Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Corrective Actions Taken or Planned: Recently we implemented and communicated a revised Procurement policy that reinstates the requirement of 3 competitive bids if the requisition amount is over $10K. NSC will ensure reinforcement of this policy through multiple layers of review (Legal, Accounting and Executives). Although, the policy was recently reinstated NSC will ensure that it will abide to the policy as much as is possible for all purchases prior to November 1st. In order to facilitate and implement the new procurement policy, NSC will utilize ERP system AVID which helps create approval routings through automated workflows. Accounting, Legal and up to the VP level will ensure and review proper documentation. The CFO and COO will be the final line of review prior to ultimate approval for all purchases above the VP delegation level of authority. The following approvals are required for procurements for items up to: 15K by VP?s of business units 50K by CFO, 100K by COO, Over $100K by CEO. A thorough review of Federal grants will be performed and a new standard operating procedure created, to ensure that all federal ruled are properly being followed as part of the procurement policy. Finally, multiple training sessions and communications to all affected staff will be conducted in order to ensure future compliance at all levels. Anticipated completion date: October 27th 2022 Individual Responsible: Ron Hausner, CFO

2022-002 Health Centers Cluster ? Assistance Listing No. 93.224 and 93.527 Health Center Infrastructure Support ? Assistance Listing No. 93.526 Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Procurement ? missing documentation for sole source purchase justification or price comparisons. Heartland?s purchasing policies and procedures were reviewed for content and clarity. In addition to the policy and procedure review, we will implement a more robust documentation, review, and approval process regarding larger purchases and sole sourcing. Purchases that are grant related and > $2,500 where the 3 bid minimum decision-making process is being waived and sole source is being utilized will be documented by the purchasing manager and reviewed, approved, and signed by our CEO as to why this is the optimal vendor (1). (See attached template) 2) Suspension and Debarment- missing documentation for quarterly review of vendors. Vendors will be reviewed on a quarterly basis to ensure that they are not on the exclusion list. The Accounting Specialist will report to the Controller on a quarterly basis regarding the status of the vendor review, and documentation of the review will be provided to the Controller at that time. Name(s) of the contact person(s) responsible for corrective action: Michael Cohlman, CFO and Tony Bartlett, Controller Planned completion date for corrective action plan: 4/1/23