Corrective Action Plans

CAP

Federal Award Finding: 2022-001 Material Weakness in Compliance and Internal Control over Compliance ? Procurement, Suspension and Debarment Standards Name and Contact Person: Sara Kinjo-Hischer, Tribal Administrator Corrective Action: Skagway Traditional Council will complete a checklist for procurement, based of Skagway Traditional Council?s procurement policies, to ensure that policies and procedures are followed including record retention to address procurement, suspension, and debarment standards of the Uniform Guidance. Proposed Completion Date: June 30, 2023

Finding 2022-001 Procurement, Suspension and Debarment (Repeat Finding 2021-001) Federal Agency: U.S. Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Questioned Cost: N/A Corrective Action: We agree with the auditor?s comments, and actions stated in the recommendation. The City of Evanston will: a. Implement structures to monitor external procurement service providers to ensure their procurement methods comply with applicable federal compliance requirements by: When using an external procurement services provider, Departments will review and retain procurement method and accompanying support, specifically: method of procurement (Bid, RFP, RFQ), history of procurement and accompanying support. b. Further expand Purchasing Manual to include policies and procedures for suspension and debarment searches and retaining support for suspension and debarment check by: The Purchasing Manual was revised during 2023 to incorporate procedures relating to suspension and debarment checks. The City will expand the Purchasing Manual to require suspension and debarment check support be retained in the vendor file. c. Communicate and reinforce its procurement policies and procedures to ensure compliance with applicable requirements by: Provide revised Purchasing Manual to staff with yearly reminder from Purchasing and Community Development Federal Grants Manager. d. Centralize the procurement process to ensure all departments are following applicable procedures in a uniform manner by: City staff will work with the City?s Purchasing Department to follow and adhere to applicable Procurement procedures. Contact Person: Hitesh Desai, Chief Financial Officer Anticipated Completion Date: December 31, 2023

Corrected during FY2022. In April 2022, ?approval for a noncompetitive proposal when procuring personnel-based services from a high-performing Educational Service Center? was received from ODE. Prior to this, cost comparisons from the KCESC were accepted as procurement documentation for audits, and a cost comparison was provided for FY2022. A SAM search also has been completed for the KCESC for FY23. No quotes from competing vendors were available for the Bloom Pediatric Therapy contract as no other vendor could be found to provide the service. If this occurs again in the future, a log will be kept in this situation as documentation that no other vendors are available.

December 14, 2022 Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 Finding 2022-001 U.S. Department of Education 84.370C- DC Opportunity Scholarship Program Significant Deficiency over Compliance and Internal Control over Procurement and Suspension and Debarment Planned Corrective Action: In response to last year's finding the School did implement more stringent procurement processes which include requiring the completion of a Grants Compliance Checklist prior to any spending on a federal grant. This was completed in the case of this vendor and demonstrated evidence of utilizing the simplified acquisition threshold (SAT) process was provided. However, we underestimated the amount we would spend on the the vendor. In our weekly accounting meeting, the School has implemented a process to monitor its vendors that have exceeded $20,000, to ensure year to data costs do not exceed $25,000. Beginning in September 2021, the School provided individual training to all budget managers which highlights federal and local procurement processes. We have also implemented quarterly meetings with all budget managers to ensure we are aware of upcoming expenses that may exceed the $25K threshold and/or incremental expenses that may exceed $25K with one vendor. Finally, we are proactively bidding out all contracts that exceeded $25K last year. Name of Contact Person: Tiffany Godbout, COO, 202-269-6623, tiffany@aohdc.org Anticipated completion date: The Corrective Action Plan will be implemented no later than January 1, 2023.

School District U-46 Corrective Action Plan Year Ended June 30 2022 Finding 2022-001 Procurement Finding: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Corrective Action Planned: The District will obtain bids for the food commodities for the next school year and review and, if necessary, update its procedures for retaining documentation to support procurement actions. Expected Implementation Date: Spring/Summer 2023 Contact Person: Dale Burnidge

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding High School for Recording Arts agrees with the finding and will adopt a documented procurement policy consistent with the standards of 2 CFR section 200.317 through 200.320 to use for procurement of the acquisition of property or services required under federal awards or sub-awards. 3. Official Responsible for Ensuring CAP The Executive Director and Director of Operations are responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2023. 5. Plan to Monitor Completion of CAP The School Board Chair will be monitoring this CAP.

Finding Number: 2022-01 Planned Correction Action: Management will implement additional procedures to make sure suspension and debarment requirements are considered as well as additional oversight procedures to verify quotes are being obtained when required. Management reprimanded the staff who was told to obtain quotes and procurement procedures were taken away from the staff in the future. Anticipated Completion Date: 11/16/2022 Responsible Contact Person(s): Kelly Phelan, Larry Bolinger, Laura Adams

To: Sara E. Grenier, CPA Subject: Audit Finding 2022-001 COVID-19 - Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 The purpose of this memo is to respond to the FY22 Audit finding referenced in the subject matter. The auditors found that "The College did not follow their procurement policy for expenses charged to federal awards" and recommended "Management should review contracts being charged to the federal grants to ensure they have followed their procurement policy." The College concurs with the finding and recommendation and will review contracts supported by federal grants to ensure they meet institutional and Federal Guidelines. The College will also review our current procurement policies and make any adjustments that may be necessary. The estimated completion date to review contracts of this nature let between July 2022-October 2022 is no later than December 31, 2022. The action officer for this review is Robert S. Blue, Vice President for Finance and Administration & CFO.

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