Corrective Action Plans

FINDING 2024-002 Finding Subject: Child Nutrition - Procurement, Suspension, and Debarment Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but no oversight performed. There were no controls in place to ensure that the vendors included a suspension and debarment clause or check the Sam.gov website. Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number and Email Address: 765-832-2426/mwilliams@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The finance department will work in conjunction with the Food Services Director to ensure that quotes are obtained from vendors that are listed on Sam.gov or have a suspension and debarment clause before making in purchases. There will be an email thread detailing the request, the quotes, and the process for ensuring suspension and debarment. Anticipated Completion Date: Immediate.

Actions taken in response to finding: Esperanza will: 1. Sole source justification - Implement a Summary Approval and Signoff Sheet (SASS) for new contracts that documents, among other things, the justification for sole source purchases. 2. Create a pre-approved vendors list to streamline procurement while ensuring compliance. a. Require justification and periodic review for vendor inclusion 3. Review, on an annual basis, nonpersonnel costs charged to federal grants to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Ryan Gadia Planned completion date for corrective action plan: June 30, 2025

Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $146,895 in FY23 and $69,793 in FY24 for contracted occupational therapy and physical therapy services. The School Corporation did properly confirm the sample vendors were not debarred or suspended. Contact Person Responsible for Corrective Action: Shannon Current Contact Phone Number: 260-726-9341 Views of Responsible Official: We concur with the finding now that we are aware this must be done for contracted services. Prior to the audit, for at least 12 years, we were not aware this was to be done for contracted services. During prior audits, this was never brought to our attention. Description of Corrective Action Plan: Moving forward, we will make sure to solicit three quotes for contracted services that will be more than $50,000. Anticipated Completion Date: As soon as our next contracted service contract is to be entered into which will most likely be in May 2025 prior to the next school year.

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: Management became aware of the need to perform additional procedures to comply with Uniform Guidance part way through the year ended June 30, 2024 and completed the evaluation once it became known. However, by that time, the vendor was already charged to the grant prior to the completion of the vendor evaluation. UW Health has developed processes and procedures to ensure compliance with the Uniform Guidance and that evaluations are taking place prior to any vendors being charged to the grant. UW Health is also in the process of updating policy to comply with Uniform Guidance. Anticipated completion Date: June 2025 UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services and Jamie Soyk, Program Director – Financial Reporting

2024-001 (Procurement and Suspension & Debarment) Management Comments and Corrective Action: Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related to those vendors playing an important role in the Organization’s dayto- day operations. In April 2021, the Organization hired new procurement leadership and invested in Full Time Employees (FTEs) to develop a robust procurement department. Due to this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provide tools for selecting the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2025. Person Responsible for Corrective Action: Steven Beckman, CFO 45

Procurement Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) District will review procurement policies and provide additional training and education to ensure the minimum requirements of 2 CFR 200 and the procurement policies established are being followed. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

Corrective Action Planned: The federal project that has been in the works for multiple years, and, as a result, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Treasurer/Secretary

MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. District Officials responsible for the implementation of the Corrective Action Plan: Dr. Johannah Vanatta, Superintendent and Erin Bluedorn, Business Manager.

Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation did not obtain quotes from an adequate number of qualified sources. Additionally, the School Corporation did not perform a suspension and debarment check on the vendors. The sample items were for $76,200 and $31,639 worth of repair supplies in FY2023 and FY2024, respectively. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Procurement and Suspension and Debarment for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by the end of March 2025.

The district will establish a system of internal controls with the Cooperative (NISEC) to ensure formal procurement methods are properly followed.

1. Emphasis on Guideline Adherence All Purchasing Department staff will receive a formal directive reinforcing the importance of compliance with established quote requirements. This directive will emphasize: • The role of competitive pricing in responsible fiscal management. • The necessity of obtaining and documenting quotes for transparency and auditability. • The requirement to attach all quotes to the Requisition in BusinessPLUS before submission for approval. 2. Mandatory Training on Procurement Compliance To ensure full understanding of purchasing policies, the department will implement mandatory training sessions for all staff involved in the procurement process. This training will cover: • Quote requirements and thresholds per the Purchasing Manual. • Proper documentation and attachment of quotes in BusinessPLUS. • Grant-specific procurement compliance to align with funding requirements. • Consequences of non-compliance, including potential funding risks and audit findings. This training will be required for all purchasing personnel and will be completed by February 28, 2025. 3. Strengthened Supervision & Approval Processes • Purchasing Director will review and verify that quotes are attached in BusinessPLUS before approving requisitions. • A pre-submission checklist will be implemented to confirm compliance before requisition approval. • Random spot audits will be conducted on purchases exceeding $3,000 to ensure full compliance. 4. Enforcement & Accountability • Any requisition submitted without the required quotes will be rejected and returned for correction. • Repeated failure to comply with quoting policies may result in additional corrective action, including performance reviews or disciplinary measures. 5. Process Improvement & Monitoring • The Purchasing Manual will be reviewed to ensure clarity in requirements, and any needed clarifications will be communicated to relevant personnel.

Context: For the three small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $127,299 in FY23 and $25,354 in FY24 for contracted rehabilitation therapy and speech pathology services. Additionally, the School Corporation did not perform suspension and debarment checks on the sample vendors Contact Person Responsible for Corrective Action: David Rowe, Business Manager, and Ashleigh Allison, Director of Exceptional Learners Contact Phone Number: 765-298-6505 (David), 765-298-6410 (Ashleigh) Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Acquire and document quotes/bids from the necessary number of vendors for projects requiring bids. In addition, suspension and debarment checks will be performed on the sample vendors, with documentation of the checks being maintained. Anticipated Completion Date: Begin immediately, ongoing.

Finding 2024-002- Moving to Work Demonstration ALN 14.881 - Procurement- Formal Competitive Requirements - Noncompliance & Significant Deficiency Noncompliance & Significant Deficiency Movingto Work Demonstration - ALN #14.881 Corrective Action Plan: We will have staff attend procurement training to stay connected with guidelines. We will also update our procurement policy in this fiscal year. Although we received prices for different properties, we did not anticipate, nor have we ever done roof replacement collectively for our entire portfolio. It is not uncommon to obtain pricing based on the remaining useful life of the roofs as they were not initially installed at the same time in the past. Also, as part of capital improvement planning, we consider each properties need of priorities accordingly. Person Responsible: Richard Brockington Anticipated Completion Date: June 30th, 2025

Susquehanna Township School District respectfully submits the following corrective action plan for the year ended June 30, 2024. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule: A. Compliance Findings Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Recommendation: The Subrecipient must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials and Corrective Action Planned: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now. Person Responsible: Oslwen C. Anderson, Jr., Business Manager OCA Completion Date: June 30, 2024

RESPONSIBLE OFFICIAL: SHERI PATTERSON, BUDGET & FINANCE DIRECTOR Management understands that Hood River County, as a Federal Grant recipient and a public servant, should follow formal procurement methods. The policies are in place for the County. Updates will be made in 2025 to strengthen these policies. Management will work to enforce these policies through all departments and divisions.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559, and 10.582 Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Purchasing procedures and thresholds were discussed at a leadership meeting of the Department of Food and Nutrition Services. Specifically, the need for at least two quotes for purchases between $15,000 and $50,000 was reiterated. On an ongoing basis, expenditures by vendor will be reviewed to ensure compliance with the procurement policy. Name of the contact person responsible for corrective action: Jaime Hetzler, Director of Food and Nutrition Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

In the future, we intend to advertise for a longer period of time and if needed re-advertise for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward management will be mindful of established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Name of the contact person responsible for corrective action: CFO Planned completion date for corrective action plan: January 1, 2025

2024-005 Procurement – Child Nutrition Cluster Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to our commitment to optimizing procurement practices, we have undertaken a review of our policies and procedures in accordance with Uniform Guidance and the District's Purchasing Policy. As part of this effort, we've already implemented several key enhancements to ensure that our procurement processes align with regulatory standards and organizational policies. Moreover, we've conducted an evaluation of current procedures and controls to promote consistent adherence to policies. Efforts have been made to ensure that all transactions are properly documented in accordance with district policies. These proactive measures aim to enhance our procurement framework, improve compliance, and reinforce transparency. By implementing these recommendations, our district is working towards creating a more robust and accountable procurement system, aligning with both regulatory guidelines and internal best practices. Ongoing efforts will focus on continuous improvement to further strengthen our procurement processes. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2025

Finding 2024-002 – Child Nutrition Cluster – Procurement Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An RFP will be conducted for the technology support. Anticipated Completion Date: Summer 2025

CORRECTIVE ACTION PLAN Finding 2024-001 Personnel Responsible for Corrective Action: Julie Turck, VP of Finance & Admin Anticipated Completion Date: December 31, 2024 Corrective Action Plan: LFSRM will develop a procurement policy along with procedures to follow, which will include a process of approving vendors that will be used for varying levels of purchases along with a plan to document and store quotes received and the reasoning behind the choice of vendor. Along with this there will be a plan for checking eligibility of vendors on Sam.gov.

Condition: The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements. Planned Corrective Action: This finding was due to the District having turnover among key personnel in the grants area, as well as non-adherence to policies and procedures related to grant records, grant accounting, and year-end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file. Contact person responsible for corrective action: Rusty Williams, Interim Financial Officer Anticipated Completion Date: March 31, 2025

January 5, 2024 To: Nigro & Nigro PC Regarding Audit Finding 2024-001 Procurement (5000) Assistance Listing #10.533, 10.55- U.S Department of Agriculture, California Department of Education, Child Nutrition Cluster We agree with the auditor's comments and the following actions will be taken to ensure the district is compliant with Code of Federal Regulations, CFR 200.320. 1) Implement a district system to track all formal bids, informal bids and RFQ's by contract year 2) Documents will include key information such as bid solicitation dates, contract dates and renewal dates for all Nutrition Services bids, RFPs, RFQs and micro-purchases. 3) The Director of NUtrition Services will review all contracts at the beginning of each school year. These steps along with training key personnel will make sure we are in compliance with Code of Federal Regulations, CFR 200.320 Michelle Cagle Director, Fiscal Services

Finding 2024-003 Procurement, Suspension, & Debarment Significant Deficiency in Internal Control over Compliance Criteria Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.591 Program Name: Family Violence Prevention and Services/State Domestic Violence Coalitions Finding Summary: 2 CFR 200.303(a) establishes that the auditee must create and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. There were two instances where the review and approval process did not identify the procurement worksheet was incorrectly completed. In addition, the contracts tested did not include some of the required contract provisions. Corrective Action Plan: Completed. Management agrees that the procurement worksheet was incorrectly completed, and training has taken place with agency staff to ensure accurate completion of the required documentation. Responsible Individual: Krista Heeren-Graber, Executive Director Anticipated Completion Date: Completed

Finding Number 2024-001 Contact Person(s): Jonathan Smith, Director of Finance R ecommendation: Subsequent to June 30, 2024, we noted the Organization requested and received explicit approval from the United States Department of State to use the noncompetitive procurement method for the procurement transaction tested. We recommend that the Organization implement measures to ensure that proper justification be determined and documented when utilizing the noncompetitive procurement method for the procurement transaction tested. C orrective action planned: Landesa will work to train program staff on non-competitive procurement use cases, and the documentation required to support these type of transactions. Additionally, Landesa will implement procurement software to automate workflows and approval processes for non-competitive procurement. Anticipated completion date: January 2025