Corrective Action Plans

Management Response #2022-013: Due to staff turnover in prior years and inadequate handover procedures, the Subrecipient Monitoring was not done as required. Corrective Action Plan: The Grants program management team has developed a Title X Program Manual to include a clearer Subrecipient Monitoring process that includes regular site visits and requiring supporting documentation of expenses. Furthermore, the Grants program management team will report out to the applicable internal parties on status of visits and findings on a quarterly basis. Responsible Party: Erin Flior, CDSO

FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Procurement, Suspension and Debarment Auditor Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Management/Responsible Officials and Corrective Action: The City concurs with the auditor?s recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit before and was not aware that the procurement standards identified in Title 2 of the Code of Federal Regulations (CFR), specifically 2 CFR sections 200.317 through 200.326, had to be included in the City?s procurement policy. Being that this was the first time the City received the ARPA funding and was subject to this requirement, this deficiency came up. The City will review and bring its current policy up to date. The City also made an effort to comply when a deficiency was known. In August 2022, the City established its Debarment and Suspension policy. With this policy in place, the City will review its current process to ensure that going forward, verifications for debarment and suspension are performed for contractors prior to entering into transactions with them. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023

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 2022-004 Subrecipient Monitoring Administration for Children and Families CFDA 93.566 Refugee and Entrant Assistance ? State Administered Programs Finding Summary: There was no documentation retained to support a secondary independent review was completed over the evaluation of subrecipient?s risk of noncompliance. Responsible Individuals: Nathan Beyer & Emily Lyons Corrective Action Plan: The process will be reviewed to ensure procedures are in place to include both the initial review of noncompliance, and a secondary review of that evaluation. Anticipated Completion Date: December 31, 2022

Michael Fields Agricultural Institute will work with O'Leary & Anick to establish policies and procedures to monitor subrecipient's activities in compliance with the Uniform Guidance requirements. The organization will review such policies and procedures annually or more frequently if necessary to reflect any changes. Contact Person: Shannah Schmitt, MFAI, and Kevin O'Leary, O'Leary & Anick. Anticipated date of completion: December 2023.

The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review_vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and_Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached._At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document_from SAM.GOV verifying eligibility of vendor will be attached to the vendor file.

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Denise Watters, CEO Anticipated Completion Date: December 2023 Planned Corrective Action: The Club will take immediate steps to strengthen its internal controls related to procurement of goods and services. This includes the revision of our written procurement standards to align them with federal regulations and guidelines. Additionally, we will establish procedures for maintaining adequate supporting documentation that demonstrates compliance with federal procurement standards. To ensure compliance with the prohibition on contracting with suspended or debarred parties, we will verify the status of entities with whom we enter into covered transactions using methods such as checking the System of Award Management (SAM) or collecting certifications. Responsible officials will oversee the plan's implementation, and we will maintain comprehensive records to demonstrate our commitment to adhering to federal procurement regulations and guidelines. This corrective action plan is vital to achieving and sustaining compliance with federal procurement standards.