Corrective Action Plans

FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. (See attachments)

Finding Number: 2022-001, 2021-001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Business Manager and Human Resources Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: Vendors will go through the suspension and debarment process and business office staff will assist with the process. Sealed bids will be conducted in accordance with the School policy, and the Human Resources Manager will keep documentation of the sealed bid process. The School?s procurement policy over quotes will be refined and followed. The Business Manager will review the process with business office team and department supervisors.

Recommendation: We recommend the County management establish internal controls to ensure compliance with federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finance department has met with the IT department to discuss federal procurement requirements and possible checklists. Name of the contact person responsible for corrective action: Lisa Malinski, Finance Director

November 15, 2022 Oregon Secretary of state, Audits Division 255 Capito! St. NE, Suite #500 Salem, OR 97310 Plan of Action for Multnomah Education Service District The Multnomah Education Service District respectfully submits the following corrective action plan in response to deficiencies reported In our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Talbot, Korvola and Warwick, and reported the deficiency listed below. The plan of action was adopted by the governing body at their meeting on November 15, 2022, as indicated by signatures below. Finding 2022.001: Significant deficiency Condition: The provisions for the prevailing wage rates requirements were not included in the construction contracts in excess of $2,000 financed by ESF funds and that the required certified payrolls were not obtained. The related deficiency in internal controls over compliance is considered to be a significant deficiency. As the District does not typically fund construction projects with federal fund, the District's staff were unaware of the $2,000 threshold for construction contacts financed by ESF funds to include prevailing wage rates requirements and used a threshold of $50,000, the Oregon Bureau of Labor & Industries' threshold for prevailing wage rate requirements for public works projects in Oregon. Cause: Effect or potential effect: Without adequate internal controls over wage rate requirements and Including the required provisions in construrtion contracts in excess of $2,000 financed by ESF funds, the District cannot demonstrate compliance with the wage rate requirements of the Davis-Bacon Act requirements. Questioned Costs: Questioned costs, if any, are indeterminable. Out of nine capital projects totaling $123,558, a sample of three capital projects was haphazardly selected. The capital projects were between $9,405 and $14,360 and totaled $26,024. Context; Recommendation: The District should obtain an understanding of all compliance requirements and implement controls to ensure compliance with federal wage rate requirements. Superintendent Dr. Faul Coakley Board of Directors Jessica Ariate ? Mary Botkin ? Kristin Corniielle < Katrina Doughty ? Dr. Samuel Henry ? Deny.se Peterson ? Helen Ying I !611 NE ??ns\?orth Circle ? Portland. Oregon 97220 ? (502) 255-18^1 ? MultnofiialiESD.org p!an ?? action: The Director oi Business & Operations is responsible for implementing the plan of action. All construction projects are managed by the MESD Facilities office. The Director instructed the MESD Contract and Risk Manager, meet with the Facilities office to inform staff of the Davis-Bacon prevailing wage requirements for construction contracts in excess of $ ? 2,00 . Facilities will include the consideration of Davis-Bacon requirements when reviewing a project request that is or has the potential of being federally funded. Facilities will implement the requirements of the Davis-Bacon Act as needed. Timeframe: The meeting took place on November 2, 2022. Facilities has updated their internal procedures. ? ' Multnora ESD Board Chair, Denyse Peterson Superintendent, Dr. Paul Coakley

The responsible officials within the Foundation acknowledge the findings from the 2022 audit related to our procurement practices under 2 CFR section 200.320. We understand the gravity of the situation, particularly considering that the Foundation did not have a formal procurement policy in place. To address the deficiencies identified in the audit, our planned corrective actions are foundational. Firstly, we will develop and implement a comprehensive procurement policy that adheres to the federal regulations specified in 2 CFR sections 200.318 through 200.326. This policy will provide clear and specific guidance on both competitive and noncompetitive procurement methods, establishing a framework for future procurement activities. Secondly, we recognize the paramount importance of robust documentation. Therefore, we will institute rigorous documentation procedures that mandate the thorough recording of the historical context and rationale for procurement decisions at the time of contract execution. This documentation will be meticulously maintained, adhering to the stringent requirements mandated by the federal regulations. Additionally, we will prioritize staff training to ensure that all personnel involved in the procurement process are well-informed about the new policy and are capable of consistently adhering to the documentation standards. These measures, including the creation of a procurement policy from the ground up, will enable us to rectify the audit findings promptly, establish compliance with federal regulations, and uphold the integrity of our federal award programs.

SINGLE AUDIT FINDINGS: Finding 2022-002: Procurement and Suspension and Debarment Description of Finding: The Town?s procurement standards included an incorrect threshold for small purchases as outlined in 2 CFR sections 200.318 through 200.326 ($25,000 versus $10,000). Statement of Concurrence or Nonconcurrence: There is no disagreement with the audit finding. Corrective Action: The Town will review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Name of Contact Person: Susan E. Hale, Municipal Finance Officer Projected Completion Date: June 30, 2023

U.S. Department of Housing and Urban Development 2022-01 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward?s Procurement group will add an additional layer of contract review to the department?s quarterly review process. Procurement will begin review of the activity input into the agency?s certified payroll reporting system to compare to the payments made to contractors withing the period. Any payment activity will be cross referenced with the certified payroll to ensure receipt of Davis Bacon reporting has been submitted. Procurement will work with the Property Management group to resolve any items that require follow up with the contractors as a result of the review. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson Planned completion date for corrective action plan: 12/31/2023.

Corrective Action Plan: The District has pursued education on the federal requirements regarding prevailing wage, and will make steps moving forward to ensure compliance with the federal standards relating to prevailing wage of federally financed contracts.

2022-002 ? COVID-19 ? Education Stabilization Fund ? Institutional Portion Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which its plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Planned Action Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.

Price or rate quotes will be obtained from three different sources when required by the Uniform Guidance. Doris Guzman will monitor budget projections to determine which expenses will require implementation of the appropriate level of procurement procedures that must be followed. Additionally, Hispanic Federation?s program managers will be trained on how to execute the Hispanic Federation Procurement Policy. Finally, Hispanic Federation?s new Compliance Department will review contracts to determine compliance needs.

The District will carefully review any and all compliance requirements when using federal funding for future projects. Responsible person - Nicholas Kaiser. Anticipated completion date - ongoing.

Finding: 2022-01 The College, under the direction of the Vice President of Business and Finance, is in the process of revising the existing Procurement Policy to include the required federal procurement standards set out in 2 CFR sections 200.318 through 200.326. It is anticipated that the new policy will be in place by June 30, 2023. While the requirements have not been stated in the current policy, the College believes that it is following the prescribed requirements in practice. The College understands the importance of following the guidelines and providing clear expectations in the policy. Person responsible: Lynn Miskus, Vice President for Business and Finance. Contact Information: LMISKUS@CCSJ.EDU; 1-219-473-4310

Finding # 2022-002 Immaterial noncompliance over procurement U.S. Department of Agriculture ? Rural Development 10.755 Rural Innovation Stronger Economy U.S. Department of the Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds Finding: The Organization should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 including documentation to justify when a competitive process was not used. The Organization?s procurement policies also should be expanded to incorporate the provisions of the standards referenced. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Corrective Action: Spruce Root will review the federal procurement guidelines and update its policies and procedures to be consistent with federal requirements. Anticipated Completion Date December 31, 2023

Identifying Number: 2022-002: Special Test ? Wage Rate Requirement Finding: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontract comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). The School Board did not have adequate internal controls in place to verify this compliance requirement for this particular award prior to funds being spent. School Board employees were unaware the Wage Rate Requirement was applicable for this program. Corrective Action Taken or Planned: The policy on the Uniform Grant Guidance for federal grants will be updated to be more clear on the requirements. Also, the CFO will communicate the requirements to ensure all employees responsible for federally sourced funds are adequately trained. Anticipated Implementation Date: March 1, 2023 Responsible person: Cheryl Mast

2022-001 Uniformed Guidance Written Policies and Procedures - Significant Deficiency i. Contact Person Responsible for Action: District Manager Anita Bartlett ii. Corrective Action Planned: The Powder River Conservation District (PRCD) will create a written internal control policy that coincides with federal grant requirements and contains all Uniform Guidance regulations relating to Sams.gov debarment and suspension, Davis-Bacon Wage Requirements, and other internal controls. The PRCD will also insure that district employees receive proper training/education on these regulations. iii. Anticipated Completion Date: December 31, 2023.

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

Finding No. 2022-002 Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy. Timing of Completion This corrective action has been implemented in FY23. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Brian Seabold, Director of Procurement (201) 216-8722.

Finding 2022-006 Eligibility Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The student files were not reviewed separate from preparer to determine eligibility. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The Town is in process of developing a formal policy. Name of Contact Person John Wilcox Projected Completion Date June 30, 2023

Finding 2022-005 Reporting Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The Town's Program Status Reports were not reviewed separate from preparer prior to submission. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The Town is in process of developing a formal policy. Name of Contact Person John Wilcox Projected Completion Date June 30, 2023

Finding 2022-002: COVID1-19 Education Stabilization Fund, Higher Education Emergency Relief Funds ? Procurement, Suspension and Debarment Program: COVID-19 Education Stabilization Fund (ESF) Federal Agency: U.S. Department of Education Pass Through Entity: Not Applicable Assistance Listing Number: 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Condition: The College?s policies and procedures over procurement generally conform to the requirements outlined by the Uniform Guidance. The auditors compared the College?s policies and procedures to the applicable sections of the Uniform Guidance by reviewing two vendors of a total of eleven vendors with expenditure for the ESF funds and obtained the associated supporting documentation for our selections. For one of the vendors, it was determined that the College did not obtain multiple quotes before engaging in the contract. Additionally, the auditors noted that the Institution?s procedures were not followed with regard to ensuring full and open competition, obtaining bids/quotes for the items above the micro-purchase threshold, or retaining documentation for the requirement for verifying for vendor suspension or debarment prior to contracting. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Staff responsible for procurement did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, all contracts and the related costs were appropriately reviewed for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also subsequently reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants.

Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed.

Finding 2022-004 Department of Environment Protection Agency, Passed through North Dakota Department of Environmental Quality Federal Financial Assistance Listing/CFDA Number 66.458 Clean Water State Revolving Fund Cluster Finding Summary: During the course of the engagement, Eide Bailly LLP identified that the District does not have a written policy on procurement that satisfies the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Jerry Blomeke, General Manager Corrective Action Plan: The District will establish a written policy that addresses all the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2023.

2022-005 Failure to Comply with Procurement Policy Name of contact person responsible for Corrective Action Plan: Robert Eaves, Director of Business Affairs Corrective Action Plan: The plan has commenced and the dollar minimum for Quotes has been increased from $500 to $25,000. When purchases are for $25,000 or more, three quotes will be obtained if vendors can be located for the goods or services requested. The dollar minimum will be input in the Office of Business Affairs Accounting Manual and correspondence sent to all employees via written memorandum and e-mail. Anticipated Completion Data: This process has started and we expect compliance before June 30, 2023.

To: RHR Smith From: Casco Bay Islands Transit District Subj: Corrective Action Plan Date: June 1, 2023 We are aware of the Condition identified in Section Ill - Federal Awards, Other Matters regarding 2 CFR Section 200.318 through 200.327. During your audit procedures it was identified that the District's procurement policy did not include some of the elements required by the above federal regulations. In further conversations with you, as our independent auditors, it was also discussed that based upon procurement items sampled, no non-compliance matters were noted. We have amended our CBITD Procurement Policy as of June 1, 2023 to specifically include additional required elements.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: MBDA Business Center Assistance Listing Number: 11.805 Contact Person: Carlos Valdivia, VP of Administration and Finance Anticipated Completion Date: October 31, 2022 Planned Corrective Action: The 2 CFR Part 200, Appendix XI ?Compliance Supplement? released in July 2021, did not provide guidance on which of the twelve compliances apply to the grant in question. Therefore, the AZHCC Foundation did not have the proper procurement procedures in place during the calendar year ended December 31, 2021. AZHCC received the 2021 final single audit report, which included the noncompliance with the ?Procurement and Suspension and Debarment? finding, on August 9, 2022. AZHCC implemented and put into action the proper policies on October 1, 2022. It is the AZHCC Foundation?s policy that minority and women owned businesses whose expertise match the needs of the contract get preference over other contractors. While we have worked with our vendors for many years, by virtue of the government grant source, we are constantly vetting minority business enterprises for new and diverse contractors. The following was implemented on October 1, 2022: ? The AZHCC Foundation developed policies and procedures for: o purchases that exceed the micro-purchase threshold of $10,000 but are less than the simplified acquisition threshold of $250,000. o Verification that selected vendors are not suspended or debarred. ? The AZHCC Foundation distributed policies and procedures to staff. ? The AZHCC Foundation trained staff on the new policies and procedures. It is the AZHCC position that the correction action was implemented within a timely manner, within 60 days, from the day of receiving the 2021 final audit report. None of the transactions in question for the 2022 audit finding took place after the correction action was applied.