Corrective Action Plans

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams/Amanda Myers Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation was under the assumption that the state procurement had secured the bidding/quote information for the vendor in question. Emails were given to document the ?go ahead? from our cooperative to order from the vendor. The corporation now understands that we are responsible for obtaining quotes outside of the cooperative. Anticipated Completion Date: Implemented immediately.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

Finding Number: 2022-002 Planned Corrective Action: The District is currently working with OSBA to update the policies and policy DJC states ?If feasible, all purchases over $20,000 and not otherwise subject to required federal or state bidding requirements will be based on price quotations submitted by at least three vendors.? The Treasurer and Business Manager will ensure that policy is followed when applicable. Anticipated Completion Date: October 31, 2023 Responsible Contact Person: Muata Niamke, Business Manager and Taylor Friedrich, Treasurer/CFO

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotes for vendors exceeding $10,000 from three sources. These will be reviewed and initialed by the Business Manager. For vendors with total disbursements expected to be between $50,000 and $150,000, the Food Service Director will obtain contracts from the vendors and these contracts will be stored at our Central Office. DeKalb Eastern will confirm with the Education Service Center via email or letter that the Service Center is correctly certified with the state for procurement requirements. 1f the Education Service Center remains uncertified, the Food Service Director will obtain price or rate quotes for milk from three sources. These quotes will be reviewed and initialed by the Business Manager. The Food Service Director will request a certification from vendors with contracts over $25,000 to show they are not excluded from participation in federal award programs. In the event the vendor is unable to provide a certification, DeKalb Eastern will utilize the SAM website to view the exclusions list of vendors . Anticipated Completion Date: Ongoing - The Food Service Director will obtain the necessary price and rate quotes, as well as contracts and certifications and the Business Manager will review and initial the quotes.

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate

FINDING 2022-002 Contact Person Responsible for Corrective Action: Food Service Director Billie Jo Russell Contact Phone Number: 812-755-4872 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement ? The School Corporation has established internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment requirement. The Food Service Director will obtain information from the Wilson Service Center for any necessary documentation pertaining to this requirement. The School Corporation has procured any food and supply purchases that exceed $150,000 and will maintain documentation for procurement procedures for purchases under $150,000. Suspension/Debarment ? Procedures will be implemented to ensure our procurement agent is an approved procurement agent. Anticipated Completion Date: Immediately

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INCIDENCE OF NONCOMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? ALN 10.553, 10.555, AND 10.559 2022-001 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. Independent School District No. 885 (the District) did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal procurement requirements related to the use of sealed bids and quotations. Corrective Action Plan Actions Planned ? The District will review policies and procedures relating to procurement for all federal programs to ensure that bids and/or quotations are obtained when required by the Uniform Guidance in the future. Official Responsible ? Kris Crocker, Director of Business Services. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? Kris Crocker, Director of Business Services, will assure appropriate internal controls and procedures are updated and in place to ensure compliance for future federal awards expenditures.

Views of Responsible Officials: RFE/RL Finance has provided clarification and additional guidance to Department Directors and the Procurement team to reinforce the importance of documenting the steps and decisions that result in a Sole-Source justification in the requisition process. Management has engaged Procurement consultants who have produced clear purchasing guidelines for the company including documentation requirements. RFE/RL has hired a new Procurement Director with the responsibility to improve management of the process and direction to the procurement team to ensure that support for sole source purchases is complete, maintained, and made available for review during the audit process and upon management request. Management believes that substantial progress has been made in either justifying sole source acquisitions within the limits of 2 CFR 200.320 or requiring competitive bids since the new Procurement Director has been appointed. It is Management?s intent to continue to operate in a way that removes this significant deficiency as a concern.

2022-001 Methods of Procurement Recommendation: We recommend that the County review their policies and procedures to ensure that they are operating in a manner that follows federal procurement requirements and the County?s procurement policy. The creation and use of a standard procurement checklist would assist the County in documenting all requirements for each procurement that is entered into. Management Concurs with the Finding and Recommendation Action Plan Taken in Response to Finding: The Finance Department will work with County Management and Board Departments to ensure familiarity and understanding of the County?s procurement policies and procedures. Additionally, the County is working towards the implementation of a financial system which will improve the controls in place to help ensure compliance with procurement requirements. The Finance Department is also working on a financial policies document and will would with County Manager on a review of the County?s procurement policy. Name(s) of contract person(s) responsible for corrective action: Tasha Morgan, Finance Director Planned completion date for corrective action plan: We anticipate the finding will be address by September 30, 2023

Recommendation: CLA recommends the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Dickinson County will review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Name of the contact person responsible for corrective action: Brian Bousley, Controller/Administrator Planned completion date for corrective action plan: December 31, 2023 If the State of Michigan has questions regarding this plan, please call Brian Bousley at 906-774-2573.

U.S. Department of Treasury 2022-004 COVID-19 ? Coronavirus State and Local Relief Funds (CSLRF)? Assistance Listing No. 21.027 Recommendation: The Town should review and enhance controls and procedures to ensure that it follows procurement policy for all goods and services charged to the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Town's procurement policy will be reviewed and updated to ensure compliance with federal requriements. Name(s) of the contact person(s) responsible for corrective action: Steven Repole Planned completion date for corrective action plan: 6/30/2023 If the U.S. Department of Treasury, Office of Recovery Programs has questions regarding this plan, please call Steven Repole at 410-398-4170.

CORRECTIVE ACTION PLAN Year Ended June 30, 2022 Mechanicsburg Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2022-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Greg Longwell, Director of Business Operations/CFO If there are any questions regarding this plan, please call Greg Longwell, Director of Business Operations / CFO, at 717-506-0869 or email at glongwell@mbgsd.org

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023

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

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

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

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

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

Ford County, Illinois 200 W. State St. ~ Paxton, IL 60957 Phone: (217) 379-9465 ~ Fax: (217) 379-9469 Corrective Action Plan for Current Year Findings Finding 2022-001 ? Segregation of Duties Corrective Action Plan The County?s management and County Board?s close supervision and review of accounting information is the most economical and appropriate manner to help prevent and detect errors and irregularities in the county?s accounting and financial reporting. There is no anticipated completion date for this item. Person(s) Responsible: Krisha Whitcomb, County Treasurer Timing for Implementation: There is no anticipated completion date for this item. Finding 2022-002 ? Procurement in Compliance with Uniform Guidance Corrective Action Plan The County will adopt a procurement policy in compliance with the requirements of the Uniform Guidance. Person(s) Responsible: Krisha Whitcomb, County Treasurer Timing for Implementation: November 30, 2023

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

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

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

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