Corrective Action Plans

Panthera will conduct additional training and enhance the expenses review process to ensure newly issued 2023 procurement policy guidelines are being followed.

Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.

To Whom It May Concern, As required by the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), we have provided below our response and corrective action plan addressing the finding in the Report of Independent Auditors on Compliance for the Major Federal Program and Report on Internal Control Over Compliance Required by the Uniform Guidance for the year ended September 30, 2022. Response and Corrective Action Plan Finding 2022-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2022. Cause: Management obtained rate quotations from an adequate number of vendors, but did not retain sufficient documentation and did not perform a formal assessment to proceed with the purchase. Contact Person: Marcus Martin, Director of Finance Management Response: The Marjaree Mason Center (MMC) did not correctly document the purchase of a new vehicle including having justification on the selection of the vendor. When researching the purchase of the vehicle, MMC researched different options for the vehicle, but did not keep the documentation of the research. Effective immediately, MMC has implemented new procedures when it comes to procedures for any contracts/invoices over $10,000. The Manager submitting the request much attach at least three quotes and written justification approved by the Director of Finance and/or Executive Director before the contract is signed or payments are released. Sincerely, Marcus Martin Director of Finance Marjaree Mason Center marcus@mmcenter.org

Name of Contact Person: Dr. Rosa Atkins, Interim Superintendent Corrective Action Plan: Management will implement controls to ensure that the district complies with Federal Uniform Guidance (2 CFR Section 200.320) procurement methods when expending federal awards. Proposed Completion Date: Immediately

To Whom It May Concern, As required by the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), we have provided below our response and corrective action plan addressing the finding in the Report of Independent Auditors on Compliance for the Major Federal Program and Report on Internal Control Over Compliance Required by the Uniform Guidance for the year ended July 31, 2022. Response and Corrective Action Plan Finding 2022-001: U.S. Department of Agriculture ? Foreign Agriculture Service; Market Access Program ? Assistance Listing No. 10.601; Grant period: Year Ended December 31, 2022 Cause: Management believed the vendor provided specialized services and qualified as a sole source procurement, which does not require a form of competition be performed every three years. Management Response: Management will perform an informal review process that includes obtaining quotes from similar vendors and performing a documented analysis of services and corresponding costs for the fiscal year 2022-23 and every three years going forward. Sincerely, Sara Geer Associate Director, Finance and Administration Almond Board of California

FINDING 2022-001 Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: East Noble School Corporation will attempt to solicit (3) quotes for purchases between $10,000 and $150,000. In the event we are unable to acquire the (3) quotes we will document our attempt and state the reason for which vendor we select. Suspension and Debarment: For any contract in excess of $25,000 we will solicit information from said vendor stating, ?They are not suspended or debarred from receiving Federal Funds?. This will be included in the contract or requested to be with the quote. Anticipated Completion Date: April 2023

Views of responsible officials and planned corrective actions: The District recognizes the finding as a significant deficiency. A team of administrators has been established to review federal grants on a quarterly basis and approve all expenditures. This team consists of the Superintendent, Assistant to the Superintendent, Director of Business and Operations and Assistant Business Manager. This team will review the Uniform Grant Guidance Purchasing Procedure annually. The continuous review by this team will eliminate the possibility of circumventing the internal controls and procedures in place at the district. Additionally, the District will seek guidance from the Pennsylvania Department of Education, auditors, and solicitor when questions regarding procurement arise.

Finding #2022-002 - Major Federal Award Finding - Procurement and Suspension and Debarment. Material Weakness in Internal Controls over Compliance Corrective Action Plan: Revise the current procurement policy to include federal regulations 2 CFR Section 200.317-200-326 per the thresholds in CFR 200.320. The revised policy will be reviewed with managers responsible for procurement that could potentially exceed these thresholds. A procedure will be drafted and implemented to guide managers responsible for procurement in the required procurement process based on dollar thresholds and allowable methods described in CFR 200.320. Oversight of the procurement process will be the responsibility of the EVP of Operations and the Director of Finance & Accounting.

COVID-19 Coronavirus State and Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the City implement controls to ensure its procurement policies and procedures are followed prior to entering into contracts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City acknowledges supply chain issues as a result of COVID-19 which limited purchasing options in one instance. The city will adjust business processes to provide additional review when making purchases to ensure compliance with the procurement policy and proper documentation is included for any exceptions. This will be incorporated immediately. Name of the contact person responsible for corrective action: Tiffany Hooten, Finance Director. Planned completion date for corrective action plan: July 18, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number: 812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When appropriate, the Food Services Director will employ a minimum three vendor rotation for Micro Purchases, and use effective reasoning when applicable. Director of Human Resource will review the use of these vendors on an ongoing basis. For intermediate purchases between $10,000 and $150,000, the Asst. Food Services Director will solicit at least three quotes. Once a vendor is selected, a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. For purchases over $150,000, formal bidding procedures including proper advertising and formal Board of Trustees approval. Once a vendor is selected by the Board of Trustees a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. Anticipated Completion Date: August 1, 2023

Finding 2022-004 ? Significant Deficiency Assistance Listing: 21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Federal Grantor: Department of the Treasury Compliance Requirement: Procurement and Suspension and Debarment Condition: The District used a sole source authorization for the procurement of a Type-1 Fire Engine but a competitive bid process should have been used to comply with Uniform Guidance. Recommendation: We recommend the District work with FEMA to obtain written approval for the sole source procurement, which is one of the exceptions to noncompetitive procurements. Management Response and Corrective Action Plan: The District shall revise policies and procedures to incorporate the requirements in the Uniform Guidance in its sole source approval process when it comes to selecting and approving vendors for expenditures that relates to a federal grant. The District will also work with the awarding agency to ensure written approval are obtained for sole source purchases.

FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-002 U.S. Department of Environment Protection ? Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures ? Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: This is the Authority?s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority will begin immediately to get these policies and procedures as they relate to federal programs documented in writing. The Authority is currently working with their consultants to have the written polices established and plan to have this completed within the next fiscal year. If the U.S. Department of Environmental Protection has questions regarding this plan, please contact: Mr. Kenneth Bost, Authority Chairman Alexandria Borough Water Authority PO Box 336 Alexandria, PA 16611 Phone: 814-669-4441

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with this finding as this information was unknown and the purchases made were at separate times throughout the year, were cumulative totals, and were due to unexpected equipment breakages. Suspension and Debarment and appropriate contractual controls are important to RCS and routine internal controls are in place. The one sample noted was verified in INBiz at the Indiana Secretary of State?s office as we were unaware that only Sam.gov was permissible as the verification tool. It is routine practice for RCS to verify both areas, however documentation did not exist for the Sam.gov check on this particular sample during the audit period. Description of Corrective Action Plan: The Chief Financial Officer will review with the Business Office and RCS Administrators the necessity for Suspension and Debarment compliance as well as the appropriate processes. Vendors will be checked in Sam.gov prior to any new acceptance of vendors and any new receipt of W-9 Forms. Verifications of this check will be screen prints of the Sam.gov page, dates, and initials of the employee who verified Sam.gov. Vendors who are not in good standing and are not active in Sam.gov will not be accepted for transaction in any federal fund. RCS will also try our best to coordinate contracts with vendors on purchases between $50,000 and $150,000 during the budget year. These contracts may be approved after the purchase as purchases such as this occur due to unexpected breakages or emergencies. Anticipated Completion Date: April 7, 2023

FINDING 2022-003 Person responsible for corrective actions: Courtney Halloran, Food Service Director Contact Phone Number: 765-647-4128 Views of Responsible Official: As Director of Food Service, I concur with the finding that an effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Description of Corrective Action Plan: Suspension and Debarment requirements will now be met with the use of the West Indy Co-op for use of dairy products. The Food Service Director will ensure that all vendors used for purchasing will be compliant and accessible. Milk procurement will now be done in assistance with the West Indy Co-op. Proper quotes will be documented and will reflect applicable state and local laws and regulations. Records will be maintained to include method of procurement, contract type, vendor selection and/or rejection, prices, and other quotes. The Food Service Director will ensure compliance before signing the bid agreement for the following school year. The purchasing group agreement will not be signed if procurement, suspension and debarment requirements are not met. Anticipated Completion Date: March 16, 2023 Courtney Halloran Director of Food Services March 16, 2023

Finding 2022-003 Contact Person Responsible for Corrective Action: Jennifer Anderson, Student Services/Special Education Director. Contact Number: 812-876-6325 View of the Responsible Official: Richland-Bean Blossom C.S.C. concurs with finding 2022-003. Description of Corrective Action Plan: The School Corporation will develop Internal Control procedures over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The School Corporation will develop and maintain an effective internal control system, which would include segregation of duties and would ensure compliance with requirements related to the grant agreement as well as following compliance requirements for Procurement and Suspension and Debarment. The School Corporation will have a control in place to ensure that proper procurement requirements regarding the Small Purchases threshold are met. The School Corporation will retain the appropriate amount of quotes needed and document if there is a unique situation with a vendor where quotes cannot be received. This information will be reviewed and implemented by the Corporation Treasurer, Student Services/Special Education Director or another authorized staff member. Anticipated Complete Date: Implementation of Corrective Action Plan will be set in places as of March 2023.

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

Finding 2022-010 Lack of Internal Control over Procurement Name of Contact: Roxanne Peele, Office Manager Corrective Action: HCA will adhere to financial policies and procedures and maintain documented procurement action and methods in selecting vendors for major purchases. Proposed Completion Date: 08/31/2023

Finding 2022-010 Inadequate Support for Procurement Plan: Effective September 20, 2022, the University of Illinois Chicago requires all procurement requisitions to be processed using the iBuy eProcurement system. Therefore, required procurement support is captured in the official procurement file. Expected Implementation Date: September 20, 2022

Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EOU is currently reviewing the institutional procurement process to determine if a single set of guidelines should be in place, rather than federal vs non-federal funding. Using a single set of guidelines would create a uniform procurement process, no matter the funding source, however additional options are currently being investigated. Name(s) of the contact person(s) responsible for corrective action: Haley Evans, Controller Planned completion date for corrective action plan: October 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all micro-purchases of $10,000 or less have the appropriate documentation and quotes required by Federal guidelines along with any purchases above the given thresholds based on procurement regulations. Documentation of quotes, bids, or contracts will be maintained by the GCSC Food Service manager and approved by the CFO for accuracy and completeness. A policy and procedure will be created to ensure that supporting documentation is received from the food service vendor that corresponds to any discounts or rebates received and are reflected appropriately in the billing reports. The GCSC Food Service manager will review documentation for billing accuracy prior to claims being paid and approved by the CFO. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Auditors? Recommendation - We recommend the College update its procurement policy to comply with all relevant state and local procurement requirements and review for revisions regularly. Views of Responsible Officials and Planned Corrective Action - The College agrees and will be modifying its procurement policy to address federal requirements. Responsible Official - Denise Montoya, Vice President for Finance & Administration, Theresa Storey, Chief Financial Officer and Josephine Velasquez, Chief Procurement Officer Procurement Officer Timeline and Estimated Completion Date - June 30, 2023

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the relevant audited period. The former Executive Director?s employment with HHA was terminated on October 10, 2022. The former Finance Director?s employment with HHA was terminated on October 20, 2022. The third employee?s employment with HHA was terminated on October 11, 2022. Additionally, all but two of the Board of Directors who served during the period in which the irregularities occurred have been replaced. HHA appointed the current Executive Director, Crystal Harrison (?Executive Director?), on October 10, 2022, as Interim Executive Director and promoted her to the position of Executive Director on October 26, 2022. The current Executive Director has diligently searched for all documents and records for all purchases, expenses, and cash distributions at issue during the former Executive Director?s tenure as Executive Director. However, no such documents or records were located on site at HHA?s offices or on HHA?s computers or devices. In early April 2023, HHA?s attorney served the former Executive Director, former Finance Director, and former employee with a demand to produce the missing documents and records but each responded that they had no such documents or records in their possession. Unfortunately, because of the actions of the former Executive Director, Finance Director, and employee, HHA lacks sufficient operating funds to pursue a civil suit to recover the losses caused by these former employees. Further, HHA?s errors and omissions insurance policy only covers third-party claims. As such, HHA has directed its attorney to take all appropriate action to pursue criminal charges of grand theft/embezzlement and fraud against these former employees upon completion of the audit. HHA?s attorney has already reached out to law enforcement to begin this process. Once the formal criminal complaint is filed, law enforcement will be empowered to subpoena the missing documents and records (should said documents and records still exist) from the former employees, as well as their banking and financial records (including tax returns) to track the suspicious expenses and cash distributions at issue. The current Executive Director, with the full support of HHA?s Board, is committed to taking all action necessary to ensure compliance with the rules and procedures already in place regarding expenses and cash distributions, as well as to enact new enhanced procedures for periodic reviews of these procedures to timely detect deficiencies and ensure compliance going forward. In addition, the current Executive Director will implement a process to ensure that backup records are maintained electronically as well as in a paper form.

Finding 2022-003 ? Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Scott Miller, Jill Pollard Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-003 Child Nutrition Cluster - Cafe will gather information and more bids and notate going forward. Anticipated Completion Date: June 30, 2023

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 and 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-068-PN01, 21611-068-PN01, 20619-068-PN01, 21619-068-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Noncompliance, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Special Services will conduct the search for individuals to fill the specialized or high-need positions required. If the positions are not filled by employees of Centerville-Abington Community Schools (CACS) then a search for vendors providing the services is conducted. The Director of Special Services will obtain quotes from an adequate number of qualified sources, three if possible. The quotes will be submitted to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed quotes will be maintained in each FY grant folder. The Director will also maintain a memo of the procedure for filling the specialized or high-need positions. The memo will also be reviewed by the Superintendent of CACS each year and maintained in each FY grant folder. If a vendor is selected to fill the positions the Director of Special Services will conduct the suspension & debarment search on each vendor contracted. The suspension & debarment search documents will be printed and sent to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed suspension & debarment documents will be maintained in each FY grant folder. Copies of all of A District Accredited School Corporation Since 2007 the above described reviewed, signed & dated documents will be filed in each FY grant folder maintained by the Corporation Treasurer of CACS. Responsible Party and Timeline for Completion: The Director of Special Services will conduct the search for qualified individuals or vendors to fill the specialized or high-need positions as soon as the need is identified or as positions become open. If an individual is not hired as an employee of CACS then quotes will be obtained & a vendor will be contracted. If a vendor is contracted the Director of Special Services will conduct the suspension & debarment search within three business days of selecting the vendor. All required documents will be sent to the Superintendent within three business days of receipt of each document. The Superintendent will return reviewed, signed & dated documents to the Director within three business days. Copies will be provided to the Corporation Treasurer at the same time they are sent to the Director. These procedures will be implemented immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director (FSD) will obtain a minimum of three price or rate quotes for each vendor with expected purchases of $10,000 to $150,000 each school year. Those quotes may be from vendors within and/or outside of the purchasing cooperative. Those quotes will be sent to the Assistant Superintendent who will then present those quotes with a recommendation to the School Board at a meeting open to the public. The School Board will award the appropriate vendor with the purchase of goods for the school year. The discussion, vote and award will be noted in the minutes of the school board meeting. The Assistant Superintendent will notify the FSD of the school board?s decision via email with signed & dated quotes attached. The FSD will maintain copies of all quotes including the quotes that were not accepted in each school year folder. The FSD will send suspension & debarment documents to the Assistant Superintendent for review, signature and date within three business days of selection of the vendor. The Assistant Superintendent will return the suspension & debarment documents to the FSD within three business days of receipt of the documents. The FSD will maintain all reviewed, signed & dated documents in each school year folder. Responsible Party and Timeline for Completion: The corrective action plan will take effect immediately. All tasks will be completed before each new school year begins. The FSD is responsible to obtain three rate or price quotes. The FSD will conduct the suspension & debarment search. The FSD is responsible A District Accredited School Corporation Since 2007 to maintain the files for each school year. The FSD will send all required information to the Assistant Superintendent. The Assistant Superintendent will present and make recommendations to the School Board. The Assistant Superintendent will notify the FSD of the School Board?s decision. SUMMARY