Corrective Action Plans

The following are the Ascension Parish School Board's responses and corrective action plans to the audit findings noted for the fiscal year ended June 30, 2022: 2022-001- Internal controls over procurement to sole source or professional services vendors, with which the Special Education Department enters into contracts will be strengthened with The Supply Chain Department by doing the following: ? The Supply Chain Department will ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to proc?rerttent of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f) ? Additionally, the documentation will be approved by the Director of Special Education as well as the Supervisor of Supply Chain, and retained as evidence of the internal controls over procurement. Timeline: Effective immediately Personnel Responsible: Amber Miller, Supply Chain Supervisor

* Reviewed District Procurement Policy * Reviewed 105 ILCS 5/10-20.21 State bidding requirements * Reviewed 2 CFR 200.320 procurement requirements under federal awards * Ensure all future purchases in excess of $25,000 are compliant. Contact Person - Michael Denault 618-279-7211

2022-002 ?Procurement Procedures Corrective action plan: Program directors and other employees involved with procurement will be retrained on the procurement policy. A sole source justification form will be created in conjunction with the procurement policy update that is currently in process. The Tribal Programs Administrator and Chief Financial Officer will be more diligent in ensuring program directors follow the procurement policy. Personnel responsible for corrective action: Tribal Programs Administrator (Herman Sanchez) and Chief Financial Officer (Sharon Ulibarri) Estimated corrective action completion date: September 30, 2023

#2022-004 - Compliance Finding - Procurement Recommendations: We recommend that Grand Rapids Christian Schools establish and follow written procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320. Views of Responsible Officials and Planned Corrective Actions: ? The GRCMS kitchen renovation needed to be completed quickly over the summer of 2022, and in time for the start of the 2022-23 school year (August 16, 2022). As a result, Grand Rapids Christian did not solicit quotes and contracted with Rockford Construction, who was the contractor for the GRCMS building renovation in 2014. ? GRCS will develop established written procurement standards and, when appropriate, will follow them for future projects. GRCS will utilize the resources from Uniform Guidance and 2 CFR 200 to develop a policy that is in compliance with those requirements prior to June 30, 2023.

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

Ford County, Illinois 200 W. State St. ~ Paxton, IL 60957 Phone: (217) 379-9465 ~ Fax: (217) 379-9469 Corrective Action Plan for Current Year Findings Finding 2022-001 ? Segregation of Duties Corrective Action Plan The County?s management and County Board?s close supervision and review of accounting information is the most economical and appropriate manner to help prevent and detect errors and irregularities in the county?s accounting and financial reporting. There is no anticipated completion date for this item. Person(s) Responsible: Krisha Whitcomb, County Treasurer Timing for Implementation: There is no anticipated completion date for this item. 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: Krisha Whitcomb, County Treasurer Timing for Implementation: November 30, 2023

There is no disagreement with the finding. District will follow their Procurement and Suspension and Debarment policy for small purchases and proposals by obtaining price quotes from a minimum of two vendors and maintain documentation. Name of responsible official: Kim Dax, Business Manager Expected date of completion: The planned completion date is September 1, 2022

Bonneville Power Administration: Columbia Basin Pit Tag ? Assistance Listing No. 81.999 Recommendation: CLA recommends the Commission design controls to ensure adequate documentation is maintained to support sole source justifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission completed sole source justification forms following this finding being brought to attention by the auditors. The plan for fiscal year 2023 is to review all sole source vendors to ensure there is a current and approved sole source justification form on file. Name(s) of the contact person(s) responsible for corrective action: Kathy Ameral and Michael Arredondo Planned completion date for corrective action plan: June 30, 2023

Village of Elmwood Park Corrective Action Plan for the findings identified in connection with the Single Audit for the Fiscal Year eEnding April 30, 2022 is identified below. The finding is titled and numbered consistently with the title and number assigned in the schedule of findings and questioned costs. Finding 2021-001 ? Controls over Financial Reporting Corrective Action Plan: Management agrees with the finding and recommendation and will work with GWA to correct prior year adjustments and balances. A review process for journal entries is in place and will be reevaluated. Interfunds are being tracked with monthly bank recs Anticipated completion date: May 1, 2023. Contact person: Finance Director Finding 2021-002 ? Controls over Schedule of Expenditures of Federal Awards Corrective Action Plan: Management agrees with the finding and recommendation and will improve the tracking of the Revenues and Expenses of Federal Awards management. Will request missing information from GW and make sure to update and track. Anticipated completion date: May 1, 2023. Contact person: Finance Director Finding 2022-003 ? Inaccurate Bank Reconciliations Corrective Action Plan: Management agrees with the finding and recommendation and have updated the bank reconciliation process including completion of the reconciliation in the following month and tracking interfund activity with the bank reconciliation. Management will continue to evaluate the bank reconciliation process to ensure accuracy. Anticipated completion date: May 1, 2023. Contact person: Finance Director Finding 2022-004 ? Procurement Policy In Need of Updating for Federal Requirements Corrective Action Plan: Management agrees with the finding and recommendation and will discuss with the GWA and Village Attorney with the intention of making the recommended changes. Anticipated completion date: May 1, 2022. Contact person: Finance Director

Condition: In 2 of 4 sample selections of vendor purchases, the City was not able to provide evidence of properly following the procurement policy for federal awards. In 1 of the 2 failed instances, the City inappropriately designated a vendor as sole source. In 1 of the 2 failed instances, the City was unable to produce documentation for the simplified acquisition threshold related to small purchases to show procurement by sealed bids and competitive proposals. Cause: Failure to follow Federal procurement regulations. Effect: Procurement support was unavailable to demonstrate the procurement policy was followed for a vendor and an inappropriate use of sole source designation for a vendor. Recommendation: We recommend the City adhere to Federal procurement policies for federal awards to ensure proper procurement standards are followed and adhere to allowable sole source designations.

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Michael Stock, Board Chairman Planned Completion Date: Immediately.

Finding Number: 2022-001 Finding Title: Micro-Purchasing Documentation Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (Journey to Independence) Name of Contact Person Responsible for Corrective Action: Jolene Lambert, Finance and Benefits Coordinator Corrective Action Planned: To keep policies for managing sponsored projects consistent, PACT for Families Collaborative will ensure Uniform Guidance Procurement Standards for all sponsored projects. We will use an updated expenditure authorization process to assure micro-purchases are distributed equitably among qualified suppliers by updating our EAF (Expenditure Authorization Form) to include a process to assure more than one supplier is priced and documented for the most reasonable purchase. Anticipated Completion Date: Ending December 31, 2023

2022-010 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – PROCUREMENT U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Direct Payment Award Period: 2022 Recommendation: We recommend the County follow their federal purchasing policy in all of their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are program specific to ensure this properly occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will continue to work with SLFRF program managers to understand and adhere to federal purchasing policies. Name of the contact person responsible for corrective action: Peter Skwira, Finance Director Planned completion date for corrective action plan: December 31, 2023

The Town will be updating the Town's procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Responsible Individual: Patricia Chaffee, Executive Assistant. Anticipated Completion Date: January 30, 2024.

Finding 2022-003 – Inadequate Design of Monitoring Controls over Procurement Policies. Agreed. Although Hamakua Health staff were not able to provide all the procurement records required by the auditors in the short period of time that was given, these procurement documents should have been scanned by those who initiated and completed the procurement processes and kept them in a ShareFile for easier access, especially for those contracts that are still active. This will be the new standard practice for all new procurement processes. Corrective actions have been discussed and will be implemented as soon as new procurement processes are needed. Responsible persons to be contacted regarding management responses: Sharon Espejo, CFO sespejo@hamakua-health.org 808.930.2712 Catherine Marquette CEO cmarquette@hamakua-health.org 808.930.2737

Criteria: In accordance with CFR 200.318(i), the non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, in accordance with CFR 200.318(a) the nonfederal entity must have and use documented procurement procedures consistent with federal procurement standards. Condition: Expenditures tested that met the small purchase threshold (purchases with a cost between $10,000 and $250,000) did not have documentation detailing the history of procurement. Cause: The School does not have procurement policies that follow federal guidelines, specifically 2 CFR 200.320 Methods of procurement to be followed. Effect: Property and equipment additions made using federal funds during the year did not have appropriate a support showing procurement policies were followed. Questioned costs: $83,864 Context: Two out of two purchases tested for procurement did not follow federal procurement methods. Recommendation: We recommend that the School institute procurement policies whereby acquisitions follow appropriate procurement steps as required by 2 CRF 200.350 and documentation of procurement decisions is maintained. Action Plan: The School will develop a Procurement Policy that follows the formal bid process and ensures that the school is able to acquire goods based on the most advantageous balance of price, quality, and performance. The School will maintain procurement decision records in vendor files. Person Responsible: Yvonne Bullock, CEO/Head of School Policies are approved by the Board of Directors

FINDING 2022-005 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

Management Comments and Corrective Action: During the course of the single audit for the year ending August 31, 2022, it was noted that SWK "legacy" contracts did not follow the established procurement policy and procedures which requires SWK to obtain quotes from at least three sources and/or did not document the quotations in the procurement file for one expenditure between $25,000 to $100,000. This instance of noncompliance noted was for a consumer goods (i.e., clothing, and personal healthcare). Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized an existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization, hired new procurement leadership and invested Full Time Employees (FTEs) to develop a robust procurement department. As a result of this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provided tools for the selection of the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2023. Person Responsible for Corrective Action: Fred Muniz, CFO 2023

The County Council and County Executive will work through the Audit Committee and Policy Review Committee to review, update, and strengthen policies and internal controls related to County and Federal procurement policies. The County will provide sufficient training and resources for staff to make sure all County and Federal procurement policies are followed correctly. The County will also monitor these processes through internal audit procedures

Views of Responsible Officials: SAMU had a workshop for procurement practices together with Project Hope back in October/November 2022. The procurement process of Services and (nonrecurring) Goods has been updated in May/June 2023. Therein all the requirements were explained to fulfill the procurement standards established by 2 CFR 200.318. In the meantime, all procurement specialists have been advised to request a minimum of three formal quotes for procurements above $10,000, once those have been received and a proposal with an explanation (via email) of why a certain vendor has been preselected to provide the services and goods in question. With this information, the MD and Finance/Admin head are asked for internal approval and process the procurement of the Services and Goods. The approval is provided by email. An updated procurement policy is in preparation, the procurement process will be discussed again in another workshop in Q1 2024.

A Grant committee of finance, administrative, and program staff should meet regularly to centralize the review of each award. This committee will meet monthly to manage the entire life cycle of each grant. The Grant committee will set documentation standards. They should be familiar with all awards, review expenditure details, and question program staff where needed. In addition, this committee will review all reporting for accuracy and timely submission. Finally, this committee will review all reporting for accuracy and timely compliance. The committee will be in place reviewing all reporting by 12/31/2023.

Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. 2. Mary's Center will document in the procurement files some form of cost or price analysis made in connection with every procurement action. 3. For any contracted service (other than equipment-specific technical support), Mary's Center procurement file will include:  Basis for selection of the contractor,  Justification for lack of competition when competitive bids or prices are not obtained, and  Basis for award cost or price. 4. These records and files will be kept in accordance with Mary's Center's Record Retention and Document Destruction Policy.

FA 2022-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: $474 Description: A review of expenditures charged to the Child Nutrition Cluster 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: The School District has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2023 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

THE COUNCIL WILL ENSURE THAT ALL FUTURE PROCUREMENTS CORRECTLY USE AND RETAIN A PROCUREMENT SHEET WHICH DOCUMENTS THE ITEM PURCHASED, THE BIDS RECEIVED, AS WELL AS THE ANALYSIS OF THE REASONS FOR THE WINNING BID. THE WINNING CONTRACTOR/VENDOR WILL BE SEARCHED ON THE SAM WEBSITE TO DETERMINE THAT THEY ARE NOT SUSPENDED/DEBARRED.

FEDERAL AWARDS – CORRECTIVE ACTION PLAN REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT – MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition/Context: Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710