Corrective Action Plans

2022-004 U.S. Department of Justice Federal Financial Assistance Listing/Federal CFDA #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Finding Summary: It was identified that there was no observable documentation to indicate that the required procurement or suspension and debarment procedures were performed on all vendors. Lack of oversight, awareness, or understanding of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous or to suspended or debarred vendors. We recommend that the Organization maintain the appropriate documentation evidencing that procurement and suspension and debarment procedures have been completed. Status: The procurement process is relatively new to the Organization and began during the pandemic with limited staff. The Organization has hired an additional FTE in the Business Office to assist with the management of this task. Responsibility of: Jennifer Babcock, Finance Director. Estimated Completion Date: 12/31/23

Corrective Action Plan for Current Year Finding Turning Point of Central California, Inc. submits the following corrective action plan for the identified finding for the audit period July 1, 2021 through June 30, 2022: Finding 2022-001 Procurement Corrective Action: Turning Point of Central California, Inc. has updated Procurement Policy to comply with Uniform Guidance. Turning Point of Central California, Inc. is implementing procedures to obtain and retain required documentation to conform with applicable federal statutes and procurement requirements identified in 2 CFR Part 200. Person Responsible: Finance Director David Lozano. Timing for Implementation: As soon as possible prior to be effective for the fiscal year ending 6/30/24.

Views of Responsible Officials and Planned Corrective Action: Management prepared a new written procurement policy that defines all types of purchases and is in compliance with the provisions of the Uniform Guidance. This policy was implemented on July 1, 2022.

Section III - Federal Awards Findings and Questioned Costs Compliance Requirement - Procurement, Suspension and Debarment Significant Deficiency in internal control over compliance and compliance Condition: As part of compiling the Commission's population for procurements, from which a procurement sample would be selected, the Commission identified $26,432 of expenditures charged to the grant that were erroneously included in the SEFA, as the procurement methods were not eligible for federal expenditures. As a result, prior to testing compliance related to procurement, the Commission reclassified the $26,432 of expenditures from the federal grant and removed from the SEFA as of June 30,2022. Cause: The Commission's procedures did not allow for timely identification of the expenditures prior to including on the SEFA (and claiming reimbursement). Effect: A journal entry was posted to correct current year federal revenue balance as of June 30, 2022 in the amount of $26,432. Further, the Commission has applied these expenditures to future draw downs in order to reverse the expenditures that were claimed. Recommendation: We recommend that the Commission review its closing policies and procedures as well as its federal grant management procedures to ensure procurement methods are considered prior to claiming expenditures or reporting on the SEFA. Commission Response: Staff concurs with the recommendation and has reviewed and discussed procedures with finance and transit staff. The invoices are coded for expense and funding by project managers. The reimbursement of expenditures is requested based on this information. During this time period there was a shortage of staff both in the finance and transit departments. Funding requirements were reviewed with transit staff. Finance staff will strengthen the invoice process to verify project manager coding against invoicing to prevent and if necessary, timely correct funding errors. Project Managers will be responsible for reviewing monthly project manager reports that include expenditures and associated funding reimbursed.

Corrective Action Plan for Finding IC2022-001: Financial Reporting Accomack County understands the repeat finding regarding financial reporting. In our response in FY 21 to this comment we stated ?through the addition of one FTE in the FY 23 year, staff training in particular content areas such as financial reporting, pensions and OPEB reporting, and some realignment of duties with existing staff, we are able to continue internally prepared financial reports through the year and the Annual Comprehensive Financial Report (ACFR) properly and timely?. As an update, we have not been able to make a hire at this time, and have chosen to reformat the position to non-entry level and re-advertise in the spring of 2023. While an additional resource will be helpful, existing staff understanding of timing, and year- end financial reporting will continue to be both ongoing, and a priority. Accomack County Finance continues to consider financial reporting, including the year-end annual financial report a core competency and are open to suggestions in processes or protocols that will advance our capacity and capability in this area from Brown Edwards. As part of this response, County finance recognizes we are responsible for timely and accurate reporting which includes Accomack County Public Schools (ACPS) financial information and all other component units in the ACFR. As we are currently staffed, we do not have capacity for review of ACPS financial work through the year and have previously relied on their finance department. Unfortunately, that has caused delays, findings and revisions to financial exhibits several times at year end for corrections noted by the auditors. The County will explore options for reducing the aforementioned problems and thereby improving this issue as relates the ACPS financial information. Lastly, a component of the delay in FY 22 was the Landfill Closure/Post-closure liability in conjunction with Department of Environmental Quality. We have begun a specific time-line in coordination with the Deputy Director for Public Works, who has responsibility over the landfill and south transfer station so that finance has complete and approved cost information (through the DEQ process) prior to year-end each year, or just after year-end (timely). Responsible Official: Michael T. Mason, CPA, County Administrator mmason@co.accomack.va.us (757-787-5716); estimated completion date of not later than July1, 2023 for the new hire. Corrective Action Plan for Finding FA-2022-001: Procurement Accomack County Public Schools concurs with the need to maintain its Procurement Policy in concurrence with 2 CFR Part 200. The schools will review and update procurement policies to be in compliance. Responsible Official: Chris Holland, Accomack County Public Schools Superintendent, chris.holland@accomack.k12.va.us, (757)787-5759; Estimated completion date is not later than the May, 2023 School Board meeting.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2021 ? September 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of six procurements which were tested, we noted that five of them, for which the District obtained quotes using the small purchase method, did not contain documentation detailing the history of the procurement, including any other quotes obtained. Questioned Costs: ALN 84.027 - $415,251.22. Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of eight procurements which were tested, we noted that three of them did not have proper documentation for the justification of noncompetitive proposals and one of them the District did not have documentation detailing the history of the procurement, including any other quotes obtained due to the District not following the micro-purchase threshold listed in their policy. Questioned Costs: $58,198.49 Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-002 Material Weakness - Davis-Bacon Act Planned Corrective Action Proper documentation not maintained by the Authority to verify compliance with Davis Bacon, due to the lack of monitoring of contractor compliance and adequate records retention by project management. A new system of checks and balance was created between Finance, Capital Project, and Procurement Departments to reconcile, evaluate, and manage construction projects on a monthly basis to ensure proper documentation and tracking. Management will add an additional requirement to include this as part of the accounts payable process. Anticipated Completion Date Complete by September 30, 2022 Responsible Contact Person Rico Owens, Senior Accountant

2022 ? 001 ALN 14.850 Public and Indian Housing ? Special Tests & Provisions ? Wage Rate Requirements The Executive Director acknowledges the findings and the Authority?s management is currently implementing the necessary changes to remediate these noncompliance instances. Person Responsible for Correction of Finding: Pauline Sturgill, Executive Director Projected Completion Date: June 30, 2023

Finding 2022-004 Procurement Suspension and Debarment Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The City has updated the policy to be in line with Uniform Guidance. Name of Contact Person Robin Stanziale Projected Completion Date January 30, 2023

CRITERIA: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients ?must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price? 2 CFR section 200.318(i). The Center?s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The Center also has procedures to identify procurement transactions requiring competitive bids or proposals. RECOMMENDATION: We recommend the Center ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. CORRECTIVE ACTION PLAN: The Center will review its procurement policies and internal control and ensure timely action is taken when noncompliance is identified. PERSON RESPONSIBLE: Laci Herbst, Finance Department TIMELINE: Current date through succeeding reporting period.

2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID 19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Summary of Finding: The District did not obtain certified payrolls for contractor or subcontractor work performed. The District did not have internal controls in place to identify that certified payrolls were not obtained. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. Grants Department personnel met with Facilities personnel to discuss the processes and procedures to implement, and internal controls that would ensure this. These will include a monthly checklist, verified with signatures of Facilities and Grants Department Personnel. This checklist will provide verification that certified payroll is being monitored and reviewed weekly, and is being compared to prevailing wage rates. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Initial implementation of internal controls beginning on August 1. Adjustments and revisions to initial processes as needed. The verifications are to be done on a recurring monthly basis.

2022-001 - The corrective action plan was documented in our response to the auditor's comment. See the Schedule of Findings and Questioned Costs. Mark Vasina Director of Finance 402-878-3341 June 30, 2023

The Center was unaware that, in accordance with the Department of Labor (DOL)(40 USC 3141-3144, 3146, and 3147), all laborers employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for prevailing wage rates. In the future, the Center will follow the guidance of the aforementioned section and adhere to this requirement.

Auditee?s Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001: Covid 19 ? Elementary & Secondary School Emergency Relief Find II ? Special Tests and Provisions ? Wage Rate Requirements District Response: A. The District understands the requirements outlined in the Davis-Bacon Act at this time. Any future projects will be bid with Davis-Bacon requirements in the bid documentation. B. Paige Bromen, Chief Financial Officer, will review weekly wage certification sheets and compare them to applicable wage rate determinations for future projects. Additionally, Paige Bromen, Chief Financial Officer, will be responsible for assigning and documenting interviews of contractor employees and for verifying required labor postings. C. The corrective action plan will be implemented immediately January 6, 2023. Sincerely, Paige Bromen Chief Financial Officer cc: Chris Chism, Superintendent

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

2022-006 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425C220015, S425D220045, and S425C220045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that the District consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement a policy to consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. Name of the Contact Person Responsible for Corrective Action Plan: Kate Fernholz, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2023

The Daleville City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 ? Special Tests and Provisions ? Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require 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). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective January 1, 2023, stating that the Chief School Financial Officer, Linda Harper, will review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

SINGLE AUDIT FINDINGS: Finding 2022-001: Procurement and Suspension and Debarment Description of Finding: The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence: The City concurs. Corrective Action: The City will enhance their existing policies for procurement to be in accordance with Uniform Guidance Procurement Standards and plans to be adopted by June 30, 2023. Name of Contact Person: Henry Dachowitz, Chief Financial Officer Projected Completion Date: June 30, 2023

The University will review the specified requirements of the Office of Management and Budget Guidance for Grants and Agreements with the University?s grant professionals in Finance and the Office of Sponsored Programs to recommend an appendix for federal grants expenditures to the University?s procurement policy as part of the upcoming annual review.

Department of Health and Human Services FINDING ? FEDERAL AWARD PROGRAMS AUDITS 2022-002 Policies and Procedures Material Weakness Recommendation: The Organization should adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Action Taken: The Organization adopted a ?Fiscal Policies and Procedures Manual? on October 1, 2022.

Material Noncompliance Material Weakness in Internal Control over Compliance 2022-002 Procurement and Suspension and Debarment Recommendation: Recommend the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Action taken in response to finding: 1. Review and update existing Purchasing Guidelines to conform with Uniform Guidance. 2. Revise procedures for adding new vendors, implement a check for Suspension and Debarment. 3. Recommend to Board of Selectmen a revised Procurement Policy. 4. After acceptance and approval of revised procurement policy provide training to staff on new policies and procedures surrounding procurement. Name(s) of the contact person(s) responsible for corrective action: Mandi Moore, Finance Director Planned completion date for corrective action plan: 6/30/23 If anyone has questions regarding this plan, please call Mandi Moore at 860.627.1449 option 4

Item 2022-001 ? Special Tests and Provisions ? Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require 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). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective January 1, 2023, stating that the Chief School Financial Officer, Linda Harper, will review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

2022-005 - Finding Condition We noted during testing procurement, suspension, and debarment that the County doesn't have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan per Debbie Nelson, Auditor We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2023

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.