Corrective Action Plans

Finding No.: 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Guam Housing and Urban Development Authority AL Program: 14.231 Emergency Solutions Grants Program Area: Procurement and Suspension and Debarment Criteria: In accordance with applicable procurement and suspension and debarment requirements, the non-Federal entity must have and use documented procurement procedures, consistent with the Procurement Standards in 2 CFR ? 200.318-327, which require formal procurement methods when the procurement of goods or services exceeds the simplified acquisition threshold (i.e., $250,000). Condition: For one (or 20%) of five procurement transactions tested, aggregating $1,512K out of $1,519K in total non-payroll program expenditures, the small purchases method was used to procure rental of 40 rooms to be used as emergency shelters with an annual contract amount of $1,095K. Based on the contract amount, a formal procurement method should have been used in performing the procurement. Cause: Catholic Social Service (CSS) lacks controls over compliance with applicable procurement requirements. The procurement policy of CSS is not prepared in accordance with the Procurement Standards in 2 CFR 200.318-327, as it does not require formal procurement procedures for any transactions. Effect: CSS is in noncompliance with applicable procurement and suspension and debarment requirements. The total questioned cost is $1,095,000. Recommendation: CSS should establish and implement controls over compliance with applicable procurement and suspension and debarment requirements. CSS management should revisit its procurement policy for alignment with the Procurement Standards in 2 CFR 200.318-327. Views of Responsible Officials: CSS disagrees with the finding that CSS is in noncompliance with applicable procurement requirements cited in 2 CFR 200.318-327, resulting in a questioned cost of $1,095,000. The federal ESG-CV grant awarded to Guam Housing and Urban Renewal Authority (GHURA) to respond to the impact of COVID-19 pandemic provided waivers and alternative requirements, including greater flexibility, to establish expedited response actions to mitigate the spread of the coronavirus. Exhibit D of the sub-recipient agreement (SRA) provides for this reference of waivers and alternative requirements. Specifically, page 18 of Section III.F.8 of Exhibit D of the SRA states the following: ?8. Procurement. As provided by the CARES Act, the recipient may deviate from the applicable procurement standards (e.g., 24 CFR 576.407(c) and (f) and 2 CFR 200.317-200.326) when procuring goods and services to prevent, prepare for, and respond to coronavirus. If the recipient deviates from its procurement standards, then the recipient must establish alternative written procurement standards, and maintain documentation on the alternative procurement standards used to safeguard against fraud, waste, and abuse in the procurement of goods and services to prevent, prepare for, and respond to coronavirus. This alternative requirement is necessary to ensure the funds are used efficiently and effectively to prevent, prepare for, and respond to coronavirus. Notwithstanding this flexibility, the debarment and suspension regulations at 2 CFR part 180 and 2 CFR part 2424 apply as written.? The opening of a temporary emergency shelter for families and individuals who are homeless was deemed an emergency response to the coronavirus. CSS emphasizes that the focus of GHURA was to identify readily available units and obtain price quotations to stand up an emergency homeless shelter, and the ?small purchase method? would provide that information to expedite the procurement process. This process was communicated to GHURA, as well as outcome of surveys of available units, and recommendation for selection of site. CSS agrees on the recommendation to revisit CSS? procurement policy overall that would assure objectivity and cost efficiency in the purchase of goods and services, including aligning and/or adopting verbatim procurement requirements outlined in 2 CFR 200.318-327. Contact Person: Diana Calvo, Executive Director Expected Completion Date: September 30, 2023 for policy/procedure development.

Concur: Departments are responsible for the operational compliance of their grant awards. The Aviation Department is in the process of reclassifying a position to a contract compliance specialist which will help ensure future compliance. Financial Management Services (FMS) will establish a process to assist departments in meeting compliance requirements. A contract review checklist will be implemented by FMS to assist with the identification of all compliance requirements for each award. FMS currently holds grant kickoff meetings with departments, and additional focus on contract compliance will be emphasized at that time. Departments will be required to provide FMS additional compliance documentation. FMS will review the documentation for reasonableness and load the records to the PeopleSoft Project Definition page as evidence of timely compliance. As an additional measure, system reminders will be emailed to departments and FMS providing notification of upcoming deadlines. FMS will continue to provide training for grant management personnel to reinforce key concepts of grant compliance. This action plan will be completed by September 30, 2023. Contact Person: Reginald Zeno, Chief Financial Officer, FMS 817-392-8517 Contact Person: Tony Rousseau, Assistant Finance Director, FMS 817-392-8338

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Procurement 2022-001 All Federal Agencies and Programs Recommendation: The Town should 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town had an unapproved policy that complies with the procurement criteria at the time of the audit. This policy will be approved by the First Selectwoman to comply with the requirements of Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Dawn Norton Planned completion date for corrective action plan: 3/31/23 If the Office of Policy and Management has questions regarding this plan, please call Dawn Norton 203-563-0128.

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all vendors are reviewed against the debarred vendors listing prior to entering the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization currently utilizes a third-party vendor, Compliatric, to screen vendors in accordance with SAM.gov requirements on a routine basis. However, a procedure does not currently exist to ensure 100% of new vendors are entered into this separate system. A procedure is being developed to ensure that all new vendors are entered into Compliatric, and screening is completed prior to entering into a contract. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all disbursements charged to the federal follow the proper procurement standards and to maintain support for the procurement methods used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 (Continued) Action taken in response to finding: The Organization is reviewing and modifying the Purchase Requisition and Purchase Order Policy to reflect current practices more accurately, update federal regulations and associated purchase thresholds. In addition, the Organization is improving internal procedures to manage requisition submittals which reach thresholds that would dictate multiple bid submittals as well as ensure an annual training of the Organization?s management and purchasers on policy parameters. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

Program: Coronavirus State Local Fiscal Recovery Funds (SLFR) CFDA No.: 21.027 Federal Grantor: U.S. Department of Treasury Passed-through: Fresno County Award No. and Date: Fresno County Agreement 22-126, April 5, 2022 Finding 2022-003: Procurement & Suspension and Debarment Type of Finding: Material weakness in internal controls over Procurement & Suspension and Debarment and Noncompliance View of Responsible Officials: Concur with the finding. Corrective Action Plan: ? The District will establish written procurement policies and procedures as required by the Uniform Guidance (2CFR Part 200). ? The District will implement the following internal controls: 1. Review the Uniform Guidance and update the current policies and procedures to include all the requirements not part of the District?s current policies. 2. Make available the updated policies and procedures to responsible management and employees. 3. Management should monitor compliance and performance with the policies and procedures. Projected Implementation Date: June 30, 2023 Name of Responsible Person/Contact: Josh Chrisman, Administration Officer

Finding 2022-001 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund - Institutional CFDA # 84.425F Finding Summary: In the testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Responsible Individuals: Tonya Sletto Corrective Action Plan: Based on the limited amounts of Federal Awards received by the University that require procurement procedures to be applied, the University was not aware of the formal policy requirements under Uniform Guidance. We will work to adopt a policy for procurement policy that includes the requirements noted under Uniform Guidance and use that policy when federal money is being spent. Anticipated Completion Date: October 31, 2022

Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) CFDA No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Repeat Finding from Prior Year: Yes, prior year finding 2021-09. Management?s or Department?s Response: We Concur. Views of Responsible Officials and Corrective Action: Procedures have been developed and implemented to comply with the County?s policies over procurement and suspension and debarment. Name of Responsible Person: Bruce Cosby Name of Department Contact: Bruce Cosby Projected Implementation Date: July 1, 2023

Program: Airport Improvement Program CFDA No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirement Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Repeat Finding from Prior Year: Yes, prior year finding 2021-014. Management?s or Department?s Response: Concurred. Views of Responsible Officials and Corrective Action: The airport will revise the current policy to effectively ensure that the certified payroll reports are submitted timely by the contractors, subcontractors and its subs. Name of Responsible Person: Richard Sokol Name of Department Contact: Jeff Marcia Projected Implementation Date: July 1, 2023

2022-003 Contact Person Theresa Brien-Knutson, Business Manager Planned Corrective Action The District will plan to get payroll registers monthly from the contractors moving forward. Planned Completion Date June 30, 2023

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Laura Clark, the Director of Finance, is currently developing a procurement and related conflict of interest policy. These policies will be presented to the Board of Directors for approval at the July 2023 board meeting. Name of the contact person responsible for corrective action: Laura Clark, Director of Finance Planned completion date for corrective action plan: July 2023

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-003 Description of Finding Procurement and Suspension and Debarment 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action EASTCONN?s Executive Director and the Board of Directors will review, revise, and approve an updated procurement policy to incorporate required elements of the Uniform Guidance related to expenditures funded with Federal Grants. Name of Contact Person Eric S. Protulis, Executive Director Projected Completion Date November 2023

Finding 2022-002 Procurement Description of Finding The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326 and purchases were made that did not follow these requirements. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action: Corrective action will be taken to ensure the policy is updated and the correct procurement procedures are followed. Name of Contact Person: Edward B. St. John (475) 473-3352 Projected Completion Date: June 30, 2023

Finding # 2022.001 Procurement and Suspension and Debarment Response Management acknowledges the condition related to following the organization?s procurement policy guidelines. Management is taking steps to correct this condition and has identified areas in the system that will be corrected in order to follow all Federal requirements related to procurement. For example, a member of the Finance department will complete procurement training at least once a year. The Finance Department will also train all Project Managers in Procurement Policies and Procedures as needed. Responsible Party David Ayala, CFO Estimated Completion 12/31/2023

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.