Corrective Action Plans

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.

Views of Responsible Officials and Planned Corrective Action ? The Purchasing Director will update policies and procedures to specifically address procurement for federal awards. The University will also ensure that Purchasing Department and Business Office staff participate in annual federal compliance training. Timeline and Estimated Completion Date: December 2022 Responsible Party: Aaron Flure, Purchasing Director and Stephanie Gonzales, Comptroller

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Jake Roger, Town Administrator. Corrective Action Plan: The Town will produce policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Completion Date: December 31, 2023.

FINDING: 2022-002 Contact Person Responsible for Corrective Action: Deborah A. Longer, Clerk-Treasurer Contact Phone Number: (219) 942-1940 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The special purchase procurement of the CNG refuse haulers was done by Resolution of the Board of Public Works and Safety. This Resolution included references to the State Statutes permitting acquisitions of this type but did not include any reference to the Federal statutes and requirements. In addition, the Employee in Responsible Charge (ERC) and the agency assisting with the grants and purchasing failed to verify that the vendor was neither suspended nor debarred to assure they would be a qualified vendor. The City Attorney has been appraised of both of these issues. In the future, any special purchase of equipment that utilizes Federal funding will include a reference to the State and Federal statutes governing such in the City?s official action prior to moving forward and will meet all of the requirements of same. In addition, the City Attorney has included in all City contracts that the Vendor is required to provide assurances that they are a qualified vendor and not currently suspended or disbarred from doing business. In addition, each ERC will be provided a copy of the Finding 2022-02 to serve as a reminder of their responsibilities and the necessary procedures and activities related to the overseeing of the grants and direct them to review the Internal Control Policies regarding the responsibilities, procedures and activities to assure the proper reporting in all areas of the SEFA in future years. Anticipated Completion Date: April 30, 2023 Signed: Deborah A. Longer Deborah A. Longer, Clerk-Treasurer Date: April 19, 2023

U.S. Department of Housing and Urban Development Lake Wales Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-001 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority update it Procurement Policy from 2009, which was done on September 30, 2022, putting in place the procurements listed in the Uniform Guidance (UG) and clarifying procurement methods. As well as, including in the policy that all vendors? eligibility needs to be verified prior to signing contracts, either through the SAM website or by collecting a certification form from the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The new procurement policy was approved September 20, 2022 Name of the contact person responsible for corrective action: Al Kirkland, Executive Director Planned completion date for corrective action plan: Completed September 20, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Al Kirkland, Executive Director at (863)676-7414 ext. 12.

The District understands the need to properly document procurement efforts in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their procurement efforts for federal and state grants.

There is no disagreement with the finding. District will follow their Procurement policy for small purchases and proposals by obtaining price quotes from a minimum of two vendors and maintain documentation.

Finding: 2022-001 Federal Agency Name: Department of Energy, passed through Colorado Governor?s Energy Office Program Name: Weatherization Assistance for Low-Income Persons CFDA #81.042 Finding Summary: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained on one instance of single-source vendor for services provided. Responsible Individuals: Emilee Powell, Executive Director and Marcy Child, Weatherization Program Director Corrective Action Plan: Housing Resources of Western Colorado will utilize a procurement checklist to ensure that all required procurement actions are undertaken and all required documentation is obtained for procuring contracts over the micro-purchase threshold under federal awards, in order to comply with Housing Resources? procurement policy and federal compliance requirements and will conduct additional training to ensure that all staff understand which actions are considered procurement actions. Implementation date: November 1st, 2022.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Action taken in response to finding: Purchases using federal funding are reviewed to ensure compliance with 2 CFR 200 requirements. In addition, the City's procurement policy is being revised to include the requirements. Name(s) of contact person(s) responsible for corrective action: Jeri Ohman. Planned completion date for corrective action plan: July 31, 2023.

Views of Responsible Officials and Planned and Corrective Actions: Management has acknowledged the insufficient maintenance of documentation that is required to be retained for all bids and quotes. Even though most bids and quotes were received, the documentation of those bids and quotes were not maintained in a centralized location. To comply with our procurement policies, we will adjust our daily operating procedures to ensure that all bids and quotes that are obtained are retained in a centralized location that is easily accessible to the Chief Financial Officer and the assistant Chief Financial Officer.

Finding 2022-002 Condition: The auditor noted a finding in Nutrition Services in regards to procurement documentation. The District maintains written board policies regarding procurement, however they are not sufficiently developed to meet the requirements for federal procurements as required by CFR 200.320. Three procurements were identified during the fiscal year that exceeded the micro purchase threshold of $10,000. Two of the three contracts were not procured in accordance with the federal procurement requirement: one contract received only one quote, the other had no quotes. Corrective Action Plan Corrective Action Planned: The District?s Business Manager and Nutrition Supervisor researched training resources available and have selected the appropriate training for the Nutrition Supervisor to attend to obtain procurement training. A contact with Oregon Department of Education and the Oregon Child Nutrition Coalition have also been established and are available for questions as they arise. The District will also be researching and identifying other procurement trainings for all staff that have federal procurement responsibilities can attend on an annual basis. The District will also be reviewing the current procurement policies in place and identifying what needs to be updated in order for the policy to be compliant with Federal regulations. The policy will then go to the District?s Board of Directors to approve any amendments. Name of Contact Person Responsible for Corrective Action: Megan VerVaecke & Kelli Keiski Anticipated Completion Date: June 30, 2023. The Nutrition Supervisor attended training in August of 2022 that was put on through the Oregon Department of Education, USDA and the Institute of Child Nutrition. The District will continue to find additional trainings to keep up to date on procurement standards and procurement document retention. The District is also in the process of reviewing the procurement policies for compliance with Federal guidelines. An amended policy will be taken to the District?s Board of Directors within a month or two of this corrective action plan issue date.

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr Director of Finance/ShelterCare b. Catherine Fisher, Controller/ShelterCare 2. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR ?200.318, General procurement standards Identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals ii. ?200.319, Competition. requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements iii. ?200.320 Methods of procurement to be followed. 3. The anticipated completion date: a. New processes will be implemented by 05/01/2023.

Contact Person Responsible for Corrective Action: Natalie McGinnis, School Lunch Treasurer and Joe Sheffer, School Lunch Coordinator Contact Phone Number: 812-358-4271 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: Simplified Acquisition - The Lunch Fund Treasurer and the Food Services Director will solicit bids for purchases that exceed the simplified acquisition threshold of $150,000 and in the event that two bids are not received, we will obtain documentation and will present bids and documentation to the Board of School Trustees for their approval. Small Purchases - The Lunch Fund Treasurer and the Food Services Director will solicit quotes for purchases that fall within the small purchase threshold of $10,000 to $150,000 and in the event that two quotes are not received, we will obtain documentation and will present quotes and documentation for review by other employee with knowledge of the compliance requirement will sign as proof of review. Suspension and Debarment: For transactions considered covered transactions (purchases to vendors exceeding $25,000), the Lunch Fund Treasurer will conduct a SAM search to ensure that the vendor is not suspended or debarred and is eligible to participate in federally funded programs. Should the vendor be suspended or debarred, a contract will not be awarded. A copy will be kept in the Food Service Department. The Lunch Fund Treasurer and Food Service Coordinator or other employee with knowledge of the compliance requirement will sign as proof of review. Anticipated Completion Date: Immediate

Procurement ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the rationale for using noncompetitive procurement, when applicable. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? LMC staff have received further training on the use of sole source documentation, and the established policies and procedures for purchasing and procurement. ? LMC staff responsible for purchasing and agreements will follow the established policy and procedures for procurement. ? LMC staff will develop and maintain tracking mechanisms related to the methodology used for each noncompetitive procurement. Name(s) of the contact person(s) responsible for corrective action: Melissa D?Onorio, CEO, and Emily Faricy, CFO. Planned completion date for corrective action plan: January 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Micro-Purchases The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist will enter claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. Small Purchases For Small Purchases, the School Corporation will obtain 3 quotes. Documentation of the 3 quotes are kept within the financial software system or electronically. For purchases about $50,000, GCS will enter into a contract with the vendor, after verifying that the vendor is not suspended or disbarred on SAM.gov. The contract will be electronically maintained by the Purchasing Specialist and uploaded to Gateway. Exceeds Simplified Acquisitions Signed and approved contracts will be maintained and filed electronically by the Purchasing Specialist. Suspension and Debarment All contracts will include documentation from SAM.gov that the vendor has not been suspended or disbarred. Anticipated Completion Date: April 2023

MATERIAL WEAKNESSES IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE ? U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID 19 ? EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) ? FEDERAL ALN 93.323 2022-002 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. The District did not have sufficient controls in place within its COVID 19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) federal program to ensure compliance with federal procurement requirements related to methods of procurement resulting in an instance of material noncompliance. Corrective Action Plan Actions Planned ? The District will review its policies and procedures relating to procurement for its federal programs and ensure that quotations are obtained when required. Official Responsible ? The District?s Director of Business Services, Heather Aune. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? The District?s Director of Business Services, Heather Aune, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with the Uniform Guidance procurement requirements for future federal awards expenditures.