Corrective Action Plans

FINDING 2022-002 Contact Person Responsible for Corrective Action: Bryce Welsh Contact Phone Number:765-345-5101 Views of Responsible Official: We concur with the finding. While we believe that we had controls in place for this finding we failed to produce the proper documentation to prove that we did so. Description of Corrective Action Plan: Going forward we will make sure that all suspension and debarment documents are provided to the Business Manager and kept at central office. These documents will be reviewed and signed by the Business Manger showing internal controls are in place. We will also ensure that we have a contract with the vendors for purchases between $50,000 and $100,000. Anticipated Completion Date: 3/14/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jami Parks and Stacey Teipen Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The school corporation will implement internal controls to prepare, review and retain reports. The stated reporting was completed by both the Corporation Treasurer and Federal Programs Director, but the records were not initialed to show completion and review. Supporting documents will be kept as evidence of the data. Anticipated Completion Date: August 1, 2023

Audit Finding Reference Number: 2022-003 Recommendation - South Shore should develop a documented procurement policy in accordance with the uniform guidance. Corrective Action Plan - We will develop a policy as part of our overall Policy & Procedure Manual that matches all uniform guidance regulations related to procurement.

Student Financial Assistance Cluster ? CFDA No. 84.268 Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Procurement Department will offer training and reference materials to each Spend Coordinator and Grant personnel in Advancement and Accounting personnel regarding University Policy on Federal Awards. This will ensure that policy is understood and adhered to at the Department level. Communication of this training and the related policy will be sent to each Dean and the Provost. Deans will be requested to disseminate the policy and processes to Department Chairs and faculty. Internal procedures for reviewing new vendors will now include an assessment whether the purchase is grant related. The identification of a request for a purchase order for a federal grant will ensure that Procurement personnel can research, determine and document that the vendor has not been suspended or debarred. This will be documented and saved electronically. Additionally, this review process will enable Procurement personnel to advise the respective departments of adherence to the University Policy and federal regulations. In the instance where a purchase exceeds $10,000, Procurement personnel will be responsible for requesting and retaining the bidding documents from the departments. These documents will be filed electronically. Name(s) of the contact person(s) responsible for corrective action: Kyle Chapla, Director Financial Planning & Analysis and Derek Smith, Sr. Specialist, Procurement Planned completion date for corrective action plan: April 28, 2023

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

CORRECTIVE ACTION PLAN December 13, 2022 To: U.S. Department of Education Avondale Meadows Academy, Inc. d/b/a United Schools of Indianapolis respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Greenwalt CPAs, Inc. 5342 West Vermont Street Indianapolis, IN 46224 Audit period: Finding 2022-001 Identification of federal program: US DEPARTMENT OF EDUCATION 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 Contacts Governing Federally Financed and Assisted Construction) (2 CFR 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 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 200.327). Condition: An 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. Potential effect: This certain contractor may not have used the appropriate prevailing wage rate for contractors and subcontractors. Questioned costs: None. Context: A total sample of one (1) item related to a certain contractors HVAC project was selected as a part of allowable cost testing for the Education Stabilization Fund. Although the contractor did not include the appropriate prevailing wage rate clauses within the construction contracts, the contractor was able to provide certified payroll totals for the period under audit. However, the certified payrolls were not provided weekly, as required, they were provided after the project was complete. Cause: USI 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. www.unitedschoolsindy.org ~ 3980 Meadows Drive, Indianapolis, IN 46205 ~ 317.550.3363 Recommendation: We recommend that USI provide timely communication related to the prevailing wage rate requirements for contracts with future contractors. USI should also ensure that the proper prevailing wage rate clauses are included in future contracts. At the time of requesting a bid for services, management will notify all future contractors of the need for prevailing wage rate requirements and the clauses to be included in the contracts. If the U.S. Department of Justice has questions regarding this plan, please call Janie Seivers at 317.550.3363. Sincerely yours, Janie Seivers, Director of Business Affairs

FINDING 2022-007 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Requests for Reimbursements including supporting documentation, including financial and programmatic records, will be retained for a period no less than three years from the date of submission of the final expenditure report. Reimbursement Requests will be accompanied by supporting documentation to ensure expenditures are from the correct fund. Anticipated Completion Date: May 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Micro-Purchases The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist will enter claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. Small Purchases For Small Purchases, the School Corporation will obtain 3 quotes. Documentation of the 3 quotes are kept within the financial software system or electronically. For purchases about $50,000, GCS will enter into a contract with the vendor, after verifying that the vendor is not suspended or disbarred on SAM.gov. The contract will be electronically maintained by the Purchasing Specialist and uploaded to Gateway. Exceeds Simplified Acquisitions Signed and approved contracts will be maintained and filed electronically by the Purchasing Specialist. Suspension and Debarment All contracts will include documentation from SAM.gov that the vendor has not been suspended or disbarred. Anticipated Completion Date: April 2023

Finding 2022-003 Procurement, Suspension, and Debarment Material Noncompliance and Material Weakness in Internal Control over Compliance Federal Agency Name: Department of Agriculture Program Name: Child Nutrition Cluster CFDA Number: 10.553/10.555/10.555C/10.555S/10.559 Finding Summary: Eide Bailly LLP identified that the requirements of 2 CFR 200.317 through 2 CFR 200.327 were not satisfied, and the grant requirements for the procurement of food service related services were not followed. Responsible Individuals: Dr. Cory Steiner, Superintendent Corrective Action Plan: The District will review the requirements of 2 CFR 200.317 through 2 CFR 200.327 and grant provisions to ensure that all requirements are met for future periods. Anticipated Completion Date: June 30, 2023

Reporting - FFR and FSRS ? 93.982 Mental Health Disaster Assistance and Emergency Mental Health Corrective Action Plan: FSRS - start training staff on FFATA requirement and contractors during site visits . FFR - will review current procedures and continue to work with ASO and the SAMHSA Grants Management program to ensure FFR continues to be submitted early thru the PMS system. Implementation Date: Immediately Responding Officials: John Valera, Administrator and Melanie Muraoka, Administrative Officer/Alcohol and Drug Abuse Division

Reporting - FFR and FSRS ? 93.958 Block Grants for Community Mental Health Services Corrective Action Plan: AMHD plans on contracting with an accountant to assist with grant activities including preparation of FFRs. If FFRs will not be available to submit withfn 90 days after the close of the statutory grant period, a submission extension will be requested. AMHD's first-tier subawards of $30,000 or more are being currently being reported to FSRS. CAMHD has one dedicated accountant to monitor each federal grant and will ensure that the FFR includes all 1st tier sub-awards and is submitted in a timely manner. Implementation Date: AMHD - June 1, 2023 CAMHD - April 1, 2023 Responding Official: Amy Curtis, Administrative Chief and Amy Yamaguchi, Administrative Officer/Adult Mental health Division; Scott Shimabukuro, Acting Administrative Chief and Janet Ledoux, Administrative Officer/Children

Finding 2022-005 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Finding Summary: The College?s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, two vendors were not verified against the central contractor registry prior to expenses incurred to ensure the vendor was not suspended or debarred. Responsible Individuals: Dr. Lane Azure, President Corrective Action Plan: Rarely does the college use unknown vendors that have been used by the college in the past. However, we will now check with SAM to determine if vendors have been debarred or suspended. Anticipated Completion Date: July 1, 2022

Finding 2022-004 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: In our sample of reports selected for testing, we noted the following items; o No support could be provided to substantiate a secondary level of review was completed for student and institutional portion quarterly reports for the quarters ended 12/31/2021 and 3/31/2022 and the year two annual report. o Student portion quarterly reports ending 12/31/2021 and 3/31/2022 reported cumulative expenditures incurred from the inception of the federal program rather than expenditures incurred within the quarter, resulting in an error of $105,202 in the first report and $165,154 in the second report. Responsible Individuals: Dr. Lane Azure, President Corrective Action Plan: o The reporting was completed by the Comptroller. The comptroller provided the president with the report to review the report, then the report was provided to the website staff member who uploaded the report on the website in the particular area designated specifically for COVID19 reporting. The College will ensure documentation of secondary level of review and approval is retained. o The errors occurred due to a misunderstanding of how to report this particular line item. A better understanding of proper reporting requirements has been attained. All of these items were items that were not deliberately conducted by any staff member at the college. SWC blames the ever-changing method of reporting and how to spend these funds. On several occasions, the president randomly selected other TCU to see how their reporting was being done and on more than several occasions, there was no reporting to view or compare and contrast to. Anticipated Completion Date: July 1, 2022

County Judge/Executive?s Response: The two purchases made by the county were made at different times for different items. Although both purchases were paid for at the same time, due to the fiscal court approval needed to pay the bills, neither of them separately required a bid process. The County does acknowledge the $29,999.00 price tag being close to the allowable amount to spend without bidding, however, the county would state that the purchase price was agreed upon out of good faith and with no attempt to circumvent the bidding requirements. The final $30,000.00 accounted for in this section was for the rental of a dozer. The anticipated rental time and need far exceeded initial estimates. During the initial rental period, the dozer was rented to level the new soccer field, during the work on the soccer field the adjacent land was given to the county and the work on that field exceeded the initial estimates, leading to the overage. Upon realizing the amount was getting close to the $30,000.00 bid requirement the county contacted the owner of the dozer and explained the situation. At that point the owner of the dozer made an offer to sell the dozer to the county at a discounted price which would include a portion of the balance the county already owed. The county bid the purchase of a new dozer. The only bid received by the county for a dozer was from the rented dozer's owner. The county has put into place controls that will require opening of bids no matter the anticipated and/or expected outcomes in adherence to all statutory authority.

Federal Award Finding: 2022-001 Material Weakness in Compliance and Internal Control over Compliance ? Procurement, Suspension and Debarment Standards Name and Contact Person: Sara Kinjo-Hischer, Tribal Administrator Corrective Action: Skagway Traditional Council will complete a checklist for procurement, based of Skagway Traditional Council?s procurement policies, to ensure that policies and procedures are followed including record retention to address procurement, suspension, and debarment standards of the Uniform Guidance. Proposed Completion Date: June 30, 2023

Finding 2022-001 Procurement, Suspension and Debarment (Repeat Finding 2021-001) Federal Agency: U.S. Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Questioned Cost: N/A Corrective Action: We agree with the auditor?s comments, and actions stated in the recommendation. The City of Evanston will: a. Implement structures to monitor external procurement service providers to ensure their procurement methods comply with applicable federal compliance requirements by: When using an external procurement services provider, Departments will review and retain procurement method and accompanying support, specifically: method of procurement (Bid, RFP, RFQ), history of procurement and accompanying support. b. Further expand Purchasing Manual to include policies and procedures for suspension and debarment searches and retaining support for suspension and debarment check by: The Purchasing Manual was revised during 2023 to incorporate procedures relating to suspension and debarment checks. The City will expand the Purchasing Manual to require suspension and debarment check support be retained in the vendor file. c. Communicate and reinforce its procurement policies and procedures to ensure compliance with applicable requirements by: Provide revised Purchasing Manual to staff with yearly reminder from Purchasing and Community Development Federal Grants Manager. d. Centralize the procurement process to ensure all departments are following applicable procedures in a uniform manner by: City staff will work with the City?s Purchasing Department to follow and adhere to applicable Procurement procedures. Contact Person: Hitesh Desai, Chief Financial Officer Anticipated Completion Date: December 31, 2023

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-007: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: We are going to prepare written policies and procedures in accordance with Uniform Guidance. Statement of Concurrence and Responsible Persons:We concur with the auditors' finding. Kristian Rivera Santiago, Finance Director Implementation Date: May 31, 2023. See Corrective Action Plan for chart/table

The GMHA procurement policy will be updated to follow the current uniform guidance guidelines. The Housing Authority will increase the dollar amount thresholds within this policy to reflect the uniform guidelines. This policy will be revised by November 30, 2023.

Finding 2022-004 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund - Student Portion Federal Financial Assistance Listing #84.425F P425F200756-20A and P425F200756-20B Procurement, Suspension and Debarment Finding Summary: Eide Bailly LLP found that the University's procurement policy did not include all of the required elements as outlined in Uniform Guidance. Additionally, the University did not retain documentation to support the procedures it performed to ensure compliance with procurement, suspension, and debarment. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance; Elizabeth Porteous, Accountant Corrective Action Plan: Management is reviewing the Uniform Guidance set out in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II and 2 CFR 180 and will update their policies for detailed use going forward. Anticipated Completion Date: Management hopes to have the new policy in place by December 31, 2022.

2022-003 Reporting Condition: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Correction: With respect to item #1, internal controls will be implemented for a second review of all quarterly reports by a member of the business office to verify accuracy before being submitted to the Department of Education and uploaded to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021. Items #2-4 reference reports that were not reported in a timely manner. Reminders in the calendar have been created to ensure completion of the reports. Information has also been shared with the College webmaster as to when reports need to be uploaded for timely submissions. Internal controls will be used to verify accuracy of data with the financial aid office, but also a final review that shows actual submission of the reports to the Department of Education and to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021.

Management has updated their procurement policy to align with the requirements of 2 CFR 200.318

Finding 2022-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Procurement, Suspension, and Debarment Finding Summary: The Facility did not obtain quotes from multiple vendors as it relates to the procurement and purchasing of flooring which was over the micro-purchase threshold. In addition, the vendor was not verified against the central contractor registry prior to transaction inception or on a periodic basis to ensure the vendor was not suspended or debarred. Responsible Individuals: Phillip Husher, CFO, Freeman Regional Health Services Corrective Action Plan: Going forward Freeman Regional Health Services will obtain and retain quotes from multiple vendors based on our procurement policies. Documentation will be retained to support the decision of the vendor selected. Also, we will review the Central Contractor Registry to ensure vendors are not suspended or debarred before entering into covered transactions. Anticipated Completion Date: September 30th, 2023

Finding 2022-001 Program: Highway Planning and Construction Cluster CFDA Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2021-2022 Compliance Requirement(s): Procurement, Suspension, and Department Finding Summary: The City?s written policy and procedures for purchasing were not updated to incorporate the applicable Uniform Guidance requirements of sections 200.318 through 200.327 that apply to the procurement action based on the method of procurement. Responsible Individuals: Kelly Sessions, Director of Administrative Services Corrective Action Plan: The City is working to update its written procurement policies and procedures to incorporate the applicable requirements identified in sections 200.318 through 200.327 of the Uniform Guidance that apply based on the procurement action and the method of procurement as required by section 200.318(a). Anticipated Completion Date: September 30, 2023

Finding 2022-002: Procurement Policy (Material Weakness) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.318 requires that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition: FCE does not have a formal written procurement policy that conforms to the requirements of the Uniform Guidance. As a result, no procurement files were maintained to document FCE's procurement actions. Cause: FCE has no accounting policies and procedures in place to provide guidance to management on the documentary evidence requirements in accordance with proper internal controls and the Uniform Guidance. Effect or Potential Effect: Without either a procurement policy or procurement documentation, there is a risk that FCE did not perform a proper evaluation of each potential vendor whose costs were charged to federal programs. Recommendation: FCE should develop accounting policies and procedures to provide guidance to management regarding the proper internal controls over both financial reporting and compliance with federal awards. Included in those policies and procedures should be a procurement policy that conforms to the requirements of the Uniform Guidance. Furthermore, FCE should maintain documentation in its files to provide evidence to support that it followed the procurement policy. Action Taken: FCE acknowledges the requirements of the Uniform Guidance and the non-compliance implication for Federal awards. FCE is in the process of developing and implementing a procurement policy to ensure proper competitive procedures are followed with respect to its procurements, specifically its vendors. FCE will ensure that proper documentation is maintained in its files in accordance with the policy to be implemented.

2022-004: Procurement (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority implemented a procurement policy effective January 2022. Completion Date ? January 2022 Contact Person ? Jami Blosmo, Accounting Manager