Corrective Action Plans

Finding Number 2022-001 Planned Corrective Action The county administration wholeheartedly agrees that the finance staff should receive government specific accounting training. Finance department personnel will attend Government Finance Officers Association (GFOA) as provided by the Oregon chapter of GFOA. Finance personnel will also attend the annual Caselle user?s conference. Additionally, when GASB specific training is offered, Curry County personnel will attend as workshops become available. Anticipated Completion Date December 31, 2023 Responsible Contact Person Frank Jerome, Finance Director Finding Number 2022-002 Planned Corrective Action Curry County updated its procurement policy January 2023 to conform with procurement standards and establish internal controls. Anticipated Completion Date January 1, 2023. Responsible Contract Person. Anthony Pope, County Counsel.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with this finding as this information was unknown and the purchases made were at separate times throughout the year, were cumulative totals, and were due to unexpected equipment breakages. Suspension and Debarment and appropriate contractual controls are important to RCS and routine internal controls are in place. The one sample noted was verified in INBiz at the Indiana Secretary of State?s office as we were unaware that only Sam.gov was permissible as the verification tool. It is routine practice for RCS to verify both areas, however documentation did not exist for the Sam.gov check on this particular sample during the audit period. Description of Corrective Action Plan: The Chief Financial Officer will review with the Business Office and RCS Administrators the necessity for Suspension and Debarment compliance as well as the appropriate processes. Vendors will be checked in Sam.gov prior to any new acceptance of vendors and any new receipt of W-9 Forms. Verifications of this check will be screen prints of the Sam.gov page, dates, and initials of the employee who verified Sam.gov. Vendors who are not in good standing and are not active in Sam.gov will not be accepted for transaction in any federal fund. RCS will also try our best to coordinate contracts with vendors on purchases between $50,000 and $150,000 during the budget year. These contracts may be approved after the purchase as purchases such as this occur due to unexpected breakages or emergencies. Anticipated Completion Date: April 7, 2023

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: CDBG ? Entitlement Grants Cluster (14.218) Material weakness- 2022-026 Compliance with Financial and Performance Reporting See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Recommendation: The Government should review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Corrective Action Plan: The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: CDBG ? Entitlement Grants Cluster (14.218) 2022-021 Compliance with Financial and Performance Reporting Recommendation: The Government should review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Corrective Action Plan: The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.

Criteria: The Hospital must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with program requirements. Terms and conditions of the federal award require the audited financial statements to be provided to the federal agency annually within 9 months of fiscal year-end. Condition: The Hospital did not submit the audited financial statements within the prescribed period or the agency approved extended period. The audited financial statements are readily available to the federal agency through the federal clearinghouse website. Planned Corrective Action: Management agrees with the finding and is implementing procedures to ensure that the required financial reports are submitted in a timely manner in accordance with the terms and conditions of the federal award. Contact Person: Stephanie Jacobsen, CFO Anticipated Completion Date: June 30, 2023

Corrective Action Planned: The Village of Clearwater, Nebraska's management and Village Board will work on developing formal written procedures for procurement, suspension and debarment transactions. Additionally, the Village will adopt written standards of conduct covering conflicts of interest.. Anticipated Completion Date: Continuous. Responsible: Management and Village Board.

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

Finding 2022-002 Federal Agency: U.S. Department of Homeland Security Federal Financial Assistance Listing: 97.056 Applicable Federal Award Number: EMW-2019-PU-00447 & EMW-2020-PU-00288 Program Name: Port Security Grants Program Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency, Instance of Non-compliance Views of Responsible Officials: We concur. Corrective Action Plan: Review and update the District?s Procurement procedures to ensure that all required provisions are included in its contracts. Responsible Individual(s): Juan Villanueva, Director of Facilities and Procurement Anticipated Completion Date: Initial update to procurement procedures to be completed by March 31, 2023 with periodic reviews.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-004 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all micro-purchases of $10,000 or less have the appropriate documentation and quotes required by Federal guidelines along with any purchases above the given thresholds based on procurement regulations. Documentation of quotes, bids, or contracts will be maintained by the GCSC Food Service manager and approved by the CFO for accuracy and completeness. A policy and procedure will be created to ensure that supporting documentation is received from the food service vendor that corresponds to any discounts or rebates received and are reflected appropriately in the billing reports. The GCSC Food Service manager will review documentation for billing accuracy prior to claims being paid and approved by the CFO. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Finding No. 2022-006 ? HEERF Procurement Finding: During fiscal year 2022 certain costs were incurred above the micro-purchase level where there was no evidence of competitive bids received or documentation. Corrective Action Taken or Planned: The purchase noted was related to COVID testing and supplies provided by the Broad Institute. Management determined that this met the requirements of a specialty purchase, however, failed to document approval for the exception. New management is aware of this requirement for federal funds and will ensure compliance in the future. The Controller will be responsible to ensure compliance. Completed March 2023. Responsible person Richard Bowman, Controller

Finding 2002-002: Procurement Compliance Description: The Distilled Spirits Council of the U.S. recognizes the importance of implementing a procurement process in accordance with 2 CFR 200.318(a). The International Team (with feedback from the Finance Team), will adopt an updated procurement process with procedures to address various methods of procurement and ensure all vendors entered a covered transaction are not debarred, suspended, or otherwise excluded. Anticipated Completion Date: October 1, 2023 Responsible Contact Persons: Name: Kyna Ricks Position: Controller Email: kyna.ricks@distilledspirits.org Phone: 202-682-8869 Name: Robert Maron Position: Vice President, International Trade Email: robert.maron@distilledspirits.org Phone: 202-682-8826

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.

An addendum was added to the contract to complied with the required clauses.

RE: Finding 2022-001: Internal Control over Compliance The following is the Corrective Action Plan (CAP) related to the noted finding. Corrective Action Plan Agency: Colorado Department of Education Audit Period: FY21-22 Audit Finding Number: 2022-001 Audit Finding Title: Internal Control over Compliance Specific Steps to be Taken: Mountain BOCES currently utilizes a mostly decentralized purchasing system. Improved documentation and trainings relating to procurement policies and procedures as well as increased internal controls were put into place during the second half of 2022 and will continue in 2023. Mountain BOCES has been re-writing these policies to include required language and alignment with 2CFR ?? 200.317 through 200.327, particularly the requirements discussing the allowable procurement methods, dollar thresholds, and the requirements for each allowable method. The procurement policy is undergoing a major rewrite in 2023 by the Executive Director and newly hired Business Manager to ensure sufficient internal controls and overall improved efficiencies. Anticipated Completion Date: Ongoing Name(s) and Title(s) of Contact Person Wendy Wyman Executive Director responsible for Correction Action: If you should have any questions or comments, please do not hesitate to contact me at wwyman@mtnboces.org.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023

FINDING 2022-009 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Internal controls will be in place for ESSER funds so that Treasurer and Superintendent or Title I specialist will sign off on annual reports to ensure accuracy of ESSER dollars spent. Anticipated Completion Date: March 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: We will take the set aside amount and make a specific line in the financial software and report the amount that is needed as needed to be reported. The Treasurer will prepare the final expenditure report and the Title I Specialist will review the report to ensure the set asides are accurately reported. Anticipated Completion Date: March 2023

Finding 2022-002 (50000) Program: Child Nutrition Cluster CFDA Number: 10.555, 10.553 Federal Agency: U.S. Department of Agriculture Pass-through: California Department of Education Award Year: 2021-2022 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Significant Deficiency, Instance of Noncompliance Management?s or Department?s Response We concur. View of Responsible Officials and Corrective Action: Name of Responsible Person: Dr. John Pappalardo, Chief Financial Officer Correction Action Plan: We will perform revision of procurement procedures to incorporate the applicable requirements identified in sections 200.318 through 200.327 of the Uniform Guidance. Implementation Date: Fiscal Year 2022-2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

Person responsible for corrective action: County Attorney and Sheriff Corrective action planned: The County purchase policy should be followed with any expenditures exceeding $15,000. A reminder memo was sent to all offices for review. Corrective action planned: with only one SAM account for each entity, it will be the responsibility of the county offices to contact the County Clerk for verification of a vendor standing within the SAM program for federal expenditures. Anticipated completion date: August 31, 2023

CORRECTIVE ACTION PLAN Finding No. 2022-001 Procurement Federal Program: Crime Victim Assistance Assistance Listing Number: 16.575 In response to the Single Audit Finding referenced in the 2022 independent audit conducted by Donavon CPAs, Prevail will institute the following action steps to remedy the finding: ? The Interim Executive Director of Prevail, working in collaboration with Prevail?s Director of Operations, will generate a first draft of a Procurement Policy for board input and review. ? The draft will be reviewed by the Prevail Finance Committee on April 25, 2023, for input and suggestions. The Interim Executive Director will make edits in response to recommendations by the Finance Committee. ? The Procurement Plan will then be presented for board approval at the Prevail Board of Directors meeting scheduled for May 10, 2023. ? After approval, it will be the responsibility of the Director of Operations, under the oversight of the Interim Executive Director, to implement and maintain compliance with the plan. When a new Executive Director is hired, plan maintenance and compliance will become the responsibility of this role. ? On an annual basis, the Finance Committee will review the Procurement Plan to ensure Prevail maintains compliance.

We agree with the finding, This was due to the modification of assistance listing number for two awards. We will strengthen our controls for review of all grant documents before issuing the SEFA report.

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.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.