Corrective Action Plans

Recommendation: The Auditor noted the Organization should consider implementing policies, procedures, and internal controls specific to federal awards which are in writing and are approved by the appropriate level of management or those charged with governance. Planned Corrective Action: Management agrees with the recommendation and has implemented the following steps. A procurement policy, compliant with the Procurement Standards codified in 2 C.F.R. ? 200.317 through ? 200.327 has been approved by the Board of Directors. This policy states the procedures required for documentation for procurement of goods and services related to all Federal awards. Specific additional procedures have been implemented providing an additional level of review for all Federal expenditures, including a quarterly reconciliation of reporting submitted to the granter.

Finding 2022-002 ? Procurement Type of Finding: Significant Deficiency/Non-Compliance Assistance Listing Number: 93.575 (Child Care Quality Improvement) Planned Corrective Action: Effective immediately pursuant to MRGDC?s Operating Policy 10.04, Fiscal Services effective April 2022, Procurement/Purchase Order Policy and the WFSMRGB Memorandum of Understanding approved by the Chief Elected Officials and Workforce Board designating MRGDC as its Fiscal Agent, this policy will be adhered to, monitored and overseen to have strict adherence of the policy and MOU based on the approved FMGC and generally accepted accounting principles. WFSMRG?s Fiscal Policy and Procedures _001, 002, and _003 will strengthen the identified weak oversight identified the last two years when the corporate knowledge of its Fiscal Agent was reduced due to attrition of experienced staff. Training for any employee who executes a requisition for goods or services will be required and monitored for its effective implementation of the policies that provide for all the essential elements of procurement and purchasing authority that will result in the efficient and effective use of all workforce and child care funds. Responsible Staff: Executive Director(s) MRGDC, WFSMRGB MRGDC Controller MRGDC Finance Officer MRGDC Lead Accountant(s) MRGDC Accounts Payable MRGDC Director of Workforce Solutions System WFSMRGB Assistant Executive Director WFSMRGB Director of Child Care Services WFSMRGB Accountant

2022-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2023 Corrective Action: Management agrees with the finding and recommendations set forth within and is nearing completion of its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. The updated procurement policy is scheduled to be released during the third quarter of the fiscal year 2023. Training on the Uniform Guidance procurement requirements has been developed and will be required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. Last, during the first quarter of the fiscal year 2023, NeighborWorks implemented a new contracts management system that will be used to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. Full transition to the new system is targeted for the end of the fiscal year 2023.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Karen Zackfia, Director of Business and Finance Contact Phone Number: Karen Zackfia, 219-285-2228 Views of Responsible Official: I concur with the finding. Description of Corrective Action Plan: The superintendent and director of maintenance will be made aware that construction contracts in excess of $2,000 paid from federal funds must pay wages by the vendor not less than those established for the locality of North Newton School Corporation by the Department of Labor and that compliance with the Davis-Bacon Act must be in the vendor?s contract requiring weekly submissions of a copy of payroll and statement of compliance to North Newton School Corporation by the vendor as work is completed. The submission of the required documents will be one of the requirements for payment to the vendor. Anticipated Completion Date: The corrective action plan was implemented on March 15, 2023.

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