Corrective Action Plans

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the bestowal of federally procured recovery funds based upon relationship rather than merit. See, Mont. Code Ann. ? 2-2-301. To that end, the City shall draft and pass via majority vote of City Council Members a resolution to address this issue which complies with State and Federal regulation of said funds. Said resolution will be passed in 2023 prior to the conclusion of the City's fiscal year. Proposed Completion Date: Fiscal Year 2023.

The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.

Finding Number: 2022-001, 2021-002, 2020-002, 2019-007 Program Name/Assistance Listing Titles: Indian School Equalization; Indian Education Facilities, Operations, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Lolita Paddock, Principal Anticipated Completion Date: June 30, 2023 Planned Corrective Action: The School has a policy to follow the minimum general standard accounting procedures to ensure submission of accurate reports. The school administration consisting of the business manager or business services consultant will submit SF-425 reports accurately, ensuring not to include the reporting of non-federal revenues and non-federal disbursements in each quarter of reporting to the federal government.

Finding No. 2022-001: Procurement and Suspension and Debarment ? Significant Deficiency (Program Level) Finding: During testing the Federation?s controls on compliance over procurement and suspension and debarment, the Federation could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Corrective Actions Taken or Planned: Management will update its procurement policy to ensure it is in compliance with Uniform Guidance requirements and will take the additional steps of updating the policy as changes in the Uniform Guidance requirements occur. Review and monitoring is effective immediately and will be on-going beginning January 2023 and is expected to be completed by February 2023

Effective immediately, the Chief Financial Analyst has created a schedule for all Westward Heights Care Center monthly financial statements be completed and sent to the Administrator by approximately the 20th of each month. This will allow time to get the quarterly reports completed and sent to the USDA. The annual budget was not completed on time as there was a new administrator. The administrator now has the experience and education to get the budget completed by November 30th and sent to the USDA.

Finding No. 2022-004: Procurement Policy ? Material Weakness in Internal Control Over Financial Reporting; U.S. Department of Health and Human Services, Rare Disorders: Research, Surveillance, Health Promotion, and Education; Assistance Listing Number 93.315 Condition There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures, no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Recommendation It was recommended that the Association establish a written procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. It was also recommended that a review of all existing vendor or sub-awardee contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken The Spina Bifida Association will take action to ensure an up-to-date Procurement Policy is approved by the Board of Directors. Anticipated Completion Date December 2023

Finding 2022-002 Department of Transportation Airport Improvement Program, CFDA #20.106 AIP3-46-0050-57, AIP3-46-0050-61 Finding Summary: Federal share of expenditures reported within SF-425 annual report for grants #57 and #61 did not reconcile to supporting client records. Responsible Individuals: Dan Letellier, Executive Director Corrective Action Plan: Management will ensure correct support documentation is provided to 3rd party account for correct submission of FAA Forms 5100-126 and 127. Director will also verify that annual report form SF-425 is completed either by the Airport or the State of South Dakota DOT as it has been in the past. Anticipated Completion Date: Ongoing

INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START PROGRAMS LOW-INCOME HOME ENERGY and WATER ASSISTANCE PROGRAM CFDA # 93.600, 93.568 and 93.499 (Questioned Costs - Undetermined) Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the agency?s financial funding sources, the agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst?s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and uniform guidance regulations. The new automated financial system, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2023.

Finding Number: 2022-005 Condition: The Corporation's procurement procedures does not fully conform to the procurement standards identified in ?? 200.317 through 200.327. Planned Corrective Action: The procurement policies will be revised and additional education will be conducted for those individuals responsible for the procurement process. Contact person responsible for corrective action: Kristen St. Peter Anticipated Completion Date: June 2023 Management Response: Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.

U.S. DEPARTMENT OF TREASURY 2022-001 Coronavirus State and Local Fiscal Recovery Funds- ALN No. 21.027 Recommendation: We recommend the Town design and document a procurement policy in accordance with the compliance requirements outlined in Title 2 of the U.S. Code of Federal Regulations part 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the auditor?s findings. Management will design a formal procurement policy. Name(s) of the contact person(s) responsible for corrective action: Sue Nickerson, Town Accountant. Planned completion date for corrective action plan: Immediately.

2022-001: Reporting Corrective Action: Due to ever-evolving processes, LCCC did not fully comprehend all reporting nuances for the HEER program. The Comptroller and Director of Sponsored Awards will continue to perform in-depth reviews of all reporting guidance and requirements to ensure accurate reporting. Anticipated Completion Date: June 30, 2023 Contact Persons: Nola Rocha, Comptroller and Jennifer McCartney, Director of Sponsored Awards and Compliance

Finding: 2022-001 Department of Education Federal Program(s): Education Stabilization Fund- AL No. 84.425F and 84.425M Type: Significant deficiency in controls over compliance Compliance Requirement: Procurement Recommendation: We recommend the College implement a procurement policy with the requirements identified in 2 CFR Section 200.318 through 200.327. Explanation of any disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is in the process of formalizing the procurement standards noted above within its purchasing policies. Planned completion date for corrective action plan: April 30, 2023 Name(s) of the contact person(s) responsible for corrective action: Holly Higgins, Director for Business Services

Federal Procurement Requirements for Higher Education Stabilization Fund Planned Corrective Action: A policy addressing procurement standards has been created and will be implemented for future expenditures Person Responsible for Corrective Action Plan: Cindy L Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Judy Brooks, Food Service Coordinator Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Coordinator will follow our procurement procedures for all purchases. Food Service Coordinator will document that vendors for the BID are not suspended or debarred from participation in federal programs before purchasing also vendors used through the Wilson Center. The Deputy Treasurer will verify procurement and suspension and debarment documentation is on file before payment is made. When we are checking the vendors on the sams.gov website and there are no results founds then we will also request the vendor to submit a suspended and debarred form. Anticipated Completion Date: 2/13/2023

FINDING 2022-006 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. The Special Education Director will obtain pricing when cumulative costs are projected to exceed the micro purchase threshold an adequate number of qualified sources. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Anticipated Completion Date: July 31, 2023

The management team agrees with the auditor?s recommendation and has already implemented controls to address the stated concerns. Due to the public health emergency related to COVID-19, management elected to use the exception under 2 CFR 200.320(c)(3) due to the public exigency or emergency. However, management understands that the related compliance requirements have since been updated and we have adopted procedures to review any updates to compliance requirements prior to executing contracts with federal awards. Additionally, the Grants division has attended multiple trainings since the occurrence pertaining to SLFRF compliance requirements. The Grants Director also subscribes to several listserv notices to keep current on any changes in guidance. The Grants Director is responsible for the corrective action as it relates to this finding.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jennifer Farley Contact Phone Number: 765-292-2626 View of Responsible Official: I concur with the finding. COVID -19 Procurement and suspension and debarment: 1. I was unaware of these requirements at the time the money was spent. In the future I will make sure this is done correctly. Anticipated Completion Date: Done

Finding Number: 2022-002 Planned Corrective Action: See Below Anticipated Completion Date: 01/05/2023 Responsible Contact Person: Brian Haines, Treasurer 1. The Treasurer will educate all responsible parties (Director of Curriculum, Assistant Superintendent, Accounts Payable, Superintendent) in the District regarding to Federal Procurement requirements. 2. The Treasurer will ensure that all requests follow the Districts Purchasing Procedures, as well as the Federal Procurement Requirements.

FINDING:2022-003 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: In the future the Food Service Director will check on Sam.gov for any Disbarment on any purchases that is over $10,000.00. She will print it out and initial and keep on file. In the future the Food Service Director will include in their Service Agreement form #1048, for Disbarment, Suspension. The School Corporation will seek Bids/Quotes for anything over $10,00.00 in the future. If the school is not asking for Bids/Quotes for repairs, we will use the company that we have a Maintenance Agreement with. Anticipated Completion Date: February 2023

Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: 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 subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction) (2CFR section 200.327; Appendix II D to 2 CFR Part 200). 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 payroll) (29 CFR section 5.5 and 5.6; the A-102 Common Rule(section 36(i)(S)): 0MB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.327). Condition: A LEA must use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics that must meet Davis-Bacon prevailing wage requirements. Cause: The School failed to timely notify a certain contractor about the Davis-Bacon Act contract clause requirements related to the prevailing wage rate for contractors and subcontractors. As a result, the contractor did not provide the certified payrolls or statement of compliance. Potential Effect: The contractor may not have complied with the wage requirements. Questioned costs: $214,716.62. Context: A total sample of one (1) item related to a certain contractors HVAC project was selected as part of allowable cost testing for the Education Stabilization Fund. Recommendation: We recommend that the School provide timely communication related to the prevailing wage rate requirements for contracts with future contractors and subcontractors. The School should also ensure that the proper prevailing wage rate clauses are included in future contracts. We further recommend that the School ensure the contractors and subcontractors compliance with the required federal compliance requirements. Action: We concur with the recommendation and will implement the appropriate language identifying the prevailing wage rate requirements in future contracts with both contractors and subcontractors. Furthermore, certified payrolls and statements of compliance with be required and tracked for each project.

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF NARANJITO Corrective Action Plan For the Fiscal Year Ended June 30, 2022 _________________________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2021 ? June 30, 2022 Fiscal Year: 2021-2022 Principal Executive: Hon. Orlando Ortiz Chevres - Mayor Contact Person: Mrs. Belinda Alvarez, Finance Director Phone: (787) 869 - 2200 Original Finding Number: 2022-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: We are going to prepare written policies and procedures in accordance with Uniform Guidance. Implementation Date: During Fiscal Year 2022-2023. Responsible Person: Mrs. Belinda Alvarez - Finance Department Director See Corrective Action Plan for chart/table

CORRECTIVE ACTION PLAN FINDING 2022-004 Contact Person Responsible for Corrective Action: Region 8/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

Corrective Action/Auditee Views ? Management acknowledges the comment; however, was not directly involved in the purchase of the equipment as it authorized the funds to be paid to one of the supporting non-profit volunteer fire companies for the procurement of hydraulic equipment used for extrication at the scene of a vehicular accident. The town recorded the asset as is the policy to record the capital assets purchased for the non-profit fire and rescue companies that serve our residents. Management will change the purchasing policy to include a policy that all outside agencies expecting funding from the town for any purchase must adhere to the town?s purchasing policy, allow the town to directly procure the items needed, or forfeit the right of reimbursement. Anticipated Completion Date ? June 30, 2023 Contact Person ? Kelli Russ, Finance Director

Finding 2022-007: Procurement, Suspension, and Debarment Federal Agency Name: Department of Health and Human Services CFDA #93.087& 93.829 Program Name: Enhance Safety of Children Affected by Substance Abuse & Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Testing identified one contract for each of the above programs where the required contract provisions in accordance with Uniform Guidance were not included within the contract over $25,000. In addition, no documentation was retained to support management?s rationale to select both of these contracted vendors. Responsible Individuals: Project Directors (Christina Eggink-Postma, Sarah Heinrichs, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review contracts to ensure proper contract provisions are included in accordance with Uniform Guidance and the Center?s procurement policy. The CEO will document what has been reviewed and whether or not the contract has all the necessary contract requirements before contracts are executed. Anticipated Completion Date: This process was implemented beginning January 2023.

The Fiscal Officer and management company have reviewed the description of the issues and are taking steps to put stronger documentation procedures in place that will support the evaluation and selection of vendors paid from Federal programs. With respect to these specific purchases in FY22, we are confident that if the process had been appropriately documented, we would have reached similar conclusions about who was ultimately selected as the vendor for these projects. We believe the corrective actions we are taking will put us in full compliance with 2 CFR part 200 and the School?s Federal Procurement Policy in future periods.