Corrective Action Plans

Such requirements include the submission of weekly certified payrolls for each week in which any contract work is performed, to the non-federal entities. Additionally, 2 CFR 200.326 and Ark. Code Ann. § 18-44-503 require a nonfederal entity to obtain a performance bond for the public construction contract.

Condition: The District paid $1,064,887 for the installation of an HVAC system from the Education Stabilization Fund without obtaining a written contract that included the prevailing wage rate provision, and weekly certified payrolls were not submitted to the District. Additionally, the District did not publish a notice of intention to receive bids or obtain a performance bond from the contractor, as required by Ark. Code Ann. § 22-9-203 and Ark. Code Ann. § 18-44-503, respectively.

Cause: Lack of internal controls and management oversight.

Effect: The District did not comply with Wage Rate Requirements or Bonding Requirements.

Context: A total of two payments/contracts for facility repairs and improvements were paid from the Education Stabilization Fund. Both were examined.

Response: The district supplied the bidding groups with all the federal guidelines and requirements. However, we did not request or receive documentation regarding the adherence to those requirements.

Name and Contact of Person(s) Responsible: Jonathan Warren (jwarren@1hsd.org 479-783-2011)

Corrective Action: The District will contact the Arkansas Division of Elementary and Secondary Education (DESE) for guidance regarding the matter and implement proper controls

over program expenditures.

Anticipated Completion Date: June 30, 2024

The Paris School District does not dispute the findings that the previous administration did not obtain a written contract that included the prevailing wage rate clause as required by the Davis-Bacon Act for two roofing projects.

Also, the Paris School District did not obtain a performance bond for said roofing projects.

All future projects that require the requirements for Davis-Bacon will be written in the contract and include weekly certified payrolls submitted to the district by the vendors and performance bonds will be secured.

COVID 19 Coronavirus State and Local Fiscal Recovery Funds/ ALN 21.027 - Significant Deficiency - Internal Controls over Procurement Prior to purchase, Sarasota County worked with the State of Florida Medical Examiner to create and document procurement policies in conformance with the Uniform Guidance, to include sourcing of quotes, issuance of purchase orders, and certifications by vendors on acknowledgment and adherence to applicable 2 CFR requirements. The County acknowledges that the State of Florida Medical Examiner conformed with these requirements prior to purchase to include noncompetitive purchases which was further supported in a dated letter provided by the Chief Medical Examiner. The Program Division Manager, Steve Hyatt shall require and retain such additional documentation within its procurement files and will conform to sourcing this documented information for these instances prior to any future purchases. Implementation date for this process - Immediately

2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of enhancing the federal procurement policy to include sections 200.318 through 200.326. Name of the contact person responsible for corrective action: Shannon Marimón Planned completion date for corrective action plan: February 29, 2024

Specific corrective action plan for finding: Christi Walter, Coordinator Purchasing Department along with the Dom Atcitty, Grants Specialist, 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. Timeline for completion of corrective action plan: July 1, 2023 Employee position(s) responsible for meeting the timeline: Dom Atcitty, Grants Specialists; Christi Walter, CPO; Lisa Smith, Purchasing Specialist; Bellamie DeHerrera-Presley, Federal Grants Coordinator and Erica Benally, Federal Grants Specialist

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals: Rhandi Knutson, Director Corrective action plan: A procurement policy in compliance with Uniform Guidance will be approved and implemented. Anticapted Completion Date: June 30, 2024.

Views of responsible officials and planned corrective action: The Town Treasurer is working on updating the current purchasing policy. Within this policy, the Town Treasurer will implement language to reference the Uniform Guidance procurement standards.

INDING 2023-002 – DAVIS-BACON COMPLIANCE – Significant Deficiency Planned corrective action: The School through the education services provider agreement with Entrepreneurial Ventures in Education (EVE) will train operations and business office staff on thecompliance requirements under Davis-Bacon to ensure construction contracts are entered into with qualified contractors and obtain and retain appropriate certified payroll documenta􀆟on during the construction period. Responsible officers: Carlo Hershberger, Director of Finance and Accounting; Javier Dimas, Vice- President of Operations; Martha Arellano, Procurement Manager and Buyer Estimated completion date: March 15, 2024

THE DISTRICT DOES NOT HAVE DOCUMENTED PROCUREMENT PROCEDURES IN ACCORDANCE WITH THE PROCURMENT STANDARDS SET OUT AT 2 CFR SECTION 200.318 THROUGH 200.326. STATEMENT OF OCCURRENCE: MANAGEMENT AGREES WITH THE AUDIT FINDING CORRECTIVE ACTION: THE INTERIM EXECUTIVE DIRECTOR WILL DEVELOP A PROCURMENT POLICY IN ACCORDANCE WITH FEDERAL STANDARDS TO INCLUDE ALL GENERAL REQUIREMENTS SUCH AS OVERSIGHT OF CONTRACTORS' PERFORMANCE, MAINTAINING WRITTEN STANDARDS OF CONDUCT FOR EMPLOYEES INVOLVED IN CONTRACTING, AWARDING CONTRACTS ONLY TO RESPONSIBLE CONTRACTORS, MAINTAINING RECORDS TO DOCUMENT HISTORY OF PROCUREMENTS AND CONDUCTING PROCUREMENT TRANSACTIONS IN A MANNER PROVIDING FULL AND OPEN COMPETITION. PROJECTED COMPLETION DATE OF FINDING: FULL IMPLEMENTATION OF CORRECTIVE ACTION IS EXPECTED IN CALENDAR YEAR 2024. NAME OF CONTACT PERSON REGARDING FINDINGS: BRIAN KALOSKY, INTERIM EXECUTIVE DIRECTOR (860) 489-2535 BJKALOSKY@CT-TRANSWB.COM

Finding 2023-001 – Procurement and Suspension and Debarment Federal Grantor: U.S. Department of Education Pass-through Grantor: Pennsylvania Department of Education Program: Early Intervention (Philadelphia), Early Intervention (Chester) Assistance Listing #: 84.027, 84.173 Title: Special Education Cluster (IDEA) Audit Period: 07/01/2022 – 06/30/2023 Passthrough Numbers: 232-210026, 231-210026, 232-210035, 231-210035 Recommendation: We recommend Elwyn enforce its existing policy and procedures to ensure compliance with procurement requirements. Elwyn should provide targeted training to members of the organization involved in procurement processes on its existing policy and procedures to ensure understanding of the Organization’s requirements for documentation of procurement methods. Additionally, Elwyn should ensure all procurement decisions are contemporaneously documented with the information necessary to conclude on appropriateness of the procurement with respect to the procurement policy and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The purchasing department will conduct an annual training with organizational leadership regarding the Elwyn’s procurement policy. This training will help to reinforce the existing procurement documentation requirements. In addition, the purchasing department will create and distribute a purchasing checklist and tracking form that will be utilized for new procurements and renewals. This form will help to ensure that the procurement method and rationale are appropriately documented and approved by organizational personnel. The completed form will be submitted to the purchasing department for electronic storage and retention. Name of contact person responsible for corrective action: David Bowers, Vice President of Finance and Corporate Controller Email: David.bowers@elwyn.org Phone: 610-891-2028 Planned completion date for corrective action plan: June 30, 2024

Views of Responsible Officials and Planned Corrective Actions: Our management team has acknowledged the finding and is committed to ensuring that we adhere to the $10,000 threshold. To facilitate this, we will conduct a review of all vendor invoices to identify any instances where adjustments may be necessary. We will also assign a dedicated team member to review purchases on a monthly basis. This proactive measure will enable us to stay vigilant and address any potential deviations from the established threshold promptly. Moreover, if during our monthly reviews we identify that we are approaching the $10,000 threshold, we will take the initiative to seek additional quotes if necessary. Contact person responsible for corrective action: Brittany Fuentes, Director Completion date: January 4, 2024

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024

Sheila Nolan, Child Nutrition Supervisor, acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor has established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.