Corrective Action Plans

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.

Significant Deficiency ? Item No. 2022-003 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, as well as quarterly internal financial statements. Condition: The Hospital did not submit the audited financial statements within the prescribed period or request an extension and did not submit any quarterly reports to the federal agency. The Hospital was not asked for the information after they failed to submit it. The audit financial statements are readily available to the federal agency through the federal clearinghouse website. Planned Corrective Action: Management agrees with the finding and are 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. Planned Completion Date: June 30, 2023 Person Responsible: Nate Thompson, Chief Executive Officer

Finding Number: 2022-002 Planned Corrective Action: The District is currently working with OSBA to update the policies and policy DJC states ?If feasible, all purchases over $20,000 and not otherwise subject to required federal or state bidding requirements will be based on price quotations submitted by at least three vendors.? The Treasurer and Business Manager will ensure that policy is followed when applicable. Anticipated Completion Date: October 31, 2023 Responsible Contact Person: Muata Niamke, Business Manager and Taylor Friedrich, Treasurer/CFO

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotes for vendors exceeding $10,000 from three sources. These will be reviewed and initialed by the Business Manager. For vendors with total disbursements expected to be between $50,000 and $150,000, the Food Service Director will obtain contracts from the vendors and these contracts will be stored at our Central Office. DeKalb Eastern will confirm with the Education Service Center via email or letter that the Service Center is correctly certified with the state for procurement requirements. 1f the Education Service Center remains uncertified, the Food Service Director will obtain price or rate quotes for milk from three sources. These quotes will be reviewed and initialed by the Business Manager. The Food Service Director will request a certification from vendors with contracts over $25,000 to show they are not excluded from participation in federal award programs. In the event the vendor is unable to provide a certification, DeKalb Eastern will utilize the SAM website to view the exclusions list of vendors . Anticipated Completion Date: Ongoing - The Food Service Director will obtain the necessary price and rate quotes, as well as contracts and certifications and the Business Manager will review and initial the quotes.

COLEGIO LA MILAGROSA, INC. (A nonprofit organization) CORRECTIVE ACTION PLAN JUNE 30, 2022 FINDING NO. CORRECTIVE ACTION COMPLETION DATE CONTACT PERSON 2022-001: FINANCIAL STATEMENTS ? The Organization, Colegio La Milagrosa, hired a new employee. This employee is being trained to comply with the recommendations and apply them to the school year of 2021-2022. ? The Food Service area hired a new accounting company, LRR Services as of July 1, 2018 and implemented the recommendation provided by the company RRC CPA Group, PSC, and to comply with the financial processes required in the 2 CRF 200. ? Also, subsequent to June 30, 2022, an internal accountant was hired, who among other responsibilities, is coordinating and supervising the record keeping and compilation of interim and year end closing and reporting process. ? As part of our internal controls, the Food Service area has created an implemented an internal guide with procedures related for accounting processes (attached in this report). June 30th 2022 Liz M. Santiago/ Odette Y. Pacheco Torres / Lizzette Ruiz / Hector Rodriguez

CORRECTIVE ACTION PLAN October 19, 2022 Cognizant or Oversight Agency for Audit Boston Senior Home Care, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: AAFCPAs 50 Washington Street Westborough, MA 01581 Audit period: July 1, 2021 ? June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES PASSED THROUGH CITY OF BOSTON COMMISSION ON AFFAIRS OF THE ELDERLY 2022-001 National Family Caregiver Support, Title III, Part E-AL No. 93.052. Recommendation: Boston Senior Home Care, Inc. should implement a formal, Board approved, procurement policy and procedures which encompass the requirements in Federal CFR Part 200.318 through 200.327 and the Boston Age Strong Commission contract manual requirements. These procedures should be applied to any purchases made with Federal funds. In addition, BSHC should review its vendor files to ensure that appropriate procurement documentation exists throughout. Action Taken: Subsequent to the Board review of the fiscal year 2022 audit package, Boston Senior Home Care?s procurement policy will be revised to align with Federal guidelines. The policy will go to the Audit Committee or full Board for approval. If the Boston Senior Home Care, Inc. has questions regarding this plan, please call Charlie J. Webb, C.P.A. at (508) 366-9100. Sincerely yours, Jon Stumpf, Chief Financial Officer

Lack of Purchase Order Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles We will make sure that we follow our SOP and that proper controls are in place to ensure the policies and procedures are being followed. We also have a new E.D. who checks and approves every purchase order. The proper controls are now in place.

Finding 2022-002: Procurement and Suspension and Debarment Audit Finding: During testing for the Fund?s controls on compliance over procurement and suspension and debarment, the Fund could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Additionally, suspension and debarment verifications were not performed prior to entering a covered transaction. Corrective Action Plan: While The Conservation Fund?s current practice includes procuring goods and services only from reputable vendors, the Fund agrees that its procurement procedures should be strengthened. By August 2023, an update of the procurement policy will be completed to reflect all aspects of the requirements of the Uniform Guidance, and the Fund will implement steps to screen vendors for suspension and debarment. Person(s) responsible for implementation of the corrective action plan: Monica A. Garrison, Senior Vice President Finance & Treasurer. Hillina Fetehawoke, Director of Accounting & Financial Reporting.

Bonner County Clerk Michael W. Rosedale Clerk of the District Court Ex-Officio Auditor & Recorder Clerk of the Board of County Commissioners Chief Elections Officer CORRECTIVE ACTION PLAN June 5,2023 Cognizant or Oversight Agency for Audit: Department of Treasury. Bonner County respectfully submits the following corrective action plan for the year ended September 30th,2022. Name and address of independent public accounting firm: Hayden Ross. PLLC 315 S Almon St. Moscow.ID 83843 Audit Period: Year ended September 30. 2022. The findings from the September 30, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF TREASURY 2022-001 2 CFR 200.318 General Procurement Standards Recommendation: The County should expedite the provisions subject to vetting and begin following the Federal Procurement Policy and Procedures document which was adopted August 9,2022. Planned Corrective Action: The internal control oversight committee, comprised of all nine elected officials, along with the Comptroller has narrowly construed federal award purchases to fully comply with 2 CFR 200.318. This corrective action has already been addressed and is being remediated beginning May l, 2023. If the Department of Treasury has questions regarding this plan, please call Nancy Twineham or Michael Rosedale at208.265.1437. (Comptroller and Elected Clerk) Respectfully, Michael W. Rosedale Bonner County Clerk

Finding 2022-101 - Improve the Timeliness and Accuracy of Financial and Programmatic Reports (Significant Deficiency) FAL Numbers: 17.258, 17.259, 17.278 Program Title: Workforce Investment Opportunities Act (WIOA) Cluster Condition and Context: Two of three monthly programmatic reports tested were submitted past the deadline for the WIOA Cluster. Specifically, the January 2022 and June 2022 reports were submitted 9 days late and 26 days late, respectively. Recommendation: The auditors recommend that Pinal County improve controls over grant reporting that includes a process for identifying reporting requirements and monitoring the timely grant reporting. The system of control should include evaluating and documenting the reporting requirements of each grant and, assignment of both the employees responsible for preparation of the grant reports and a secondary employee assignment for overall monitoring of the timeliness of all grant reports. Contact Name: Joel Millman, WIOA Program Manager Corrective Action Planned: Although there are no excuses for untimely filing of financial reports, the issue found regarding the 2022 finding has been addressed. During the audit period, the Accountant position was in a state of transition with the previous Accountant leaving the position in June 2022. Since this staff departure, a new Accountant has been hired and subsequently underwent significant training provided by the Pinal County Budget and Finance Department as well as the Arizona Department of Economic Security?s Division of Employment and Rehabilitation?s (DES/DERS) Financial and Business Operations Administration. In order to ensure timely submittal of financial reports, new procedures have been implemented, these include cross training of the Pinal County Economic and Workforce Development Departments Administrative Specialist in monitoring financial report submittal dates. Additionally, the Accountant and Pinal County Economic and Workforce Development Department?s Workforce Development Manager meet upon receipt of contractor invoices to review and approve payment to ensure timely submittal of associated reports to DES/DERS. Of note, a fiscal review of the Workforce Innovation and Opportunity Act (WIOA), Title 1B program was conducted November 8th-10th, 2022 by the DES/DERS Business and Operations Administration. The periods selected for their testing were the periods of January 1, 2022, through April 30, 2022. The purpose of this review was to determine compliance with WIOA Title IB regulations and procedures, Department of Labor (DOL) guidelines and State policies. The review covered the areas of internal controls, general operation procedures, cash receipts and disbursements, accrued expenditures, program income, cash management, and miscellaneous items as outlined in the Fiscal Monitoring Guide. Documents reviewed within these general categories included disbursements journals, payroll journals, paid expense invoices, receipts journals, and payroll time sheets. No findings were submitted. Anticipated Completion Date: June 30, 2023

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 Hospital to maintain a reserve fund at specified balance levels. Condition: During 2022, the accounts that represented the reserve fund had a balance below that required by the loan resolution agreements and required deposits were not being made to restore the balances to required levels. Planned Corrective Action: Management agrees with the finding and will deposit required amounts into the reserve fund. Planned Completion Date: Ongoing Person Responsible: Jeremy Bauer, CEO

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023

CORRECTIVE ACTION PLAN (Concerning Finding 2022-001 & 2022-002) Contact Person Responsible for Corrective Action: Tracy Roy, Finance Director Corrective Action: The City of Lewiston will take the following actions to address finding 2022-001: The City of Lewiston has reviewed the contract and is adding the necessary sections to all contracts. Anticipated Completion Date: January 30, 2023 Corrective Action: The City of Lewiston will take the following actions to address finding 2022-002: The City of Lewiston started to require the SAM approval print out before contracts are signed with vendors beginning January 1, 2022. The Purchasing Agent or the designee will not complete the process until the SAM certification is received. The SAM document will be filed with the contract. This has been done but the employee in Economic Development gave the wrong SAM approval. Anticipated Completion Date: January 1, 2022

Finding 2022-001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing #14.134 Procurement, Suspension, and Debarment Finding Summary: The Project does not have a written procurement policy which conforms to Uniform Guidance as outlined in 2CFR 200.317 through 200.327. During the year, management entered into transactions over the micropurchase threshold with eight vendors. Documentation was unable to be provided to support procurement compliance for seven vendors. In addition, there was one vendor with expenditures in excess of $25,000 and the Project did not verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Responsible Individuals: Sue Lund, Administrator Corrective Action Plan: The Project is drafting a written procurement policy which conforms to Uniform Guidance as outlined above. In addition, for expenditures in excess of $25,000, the Project will verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Anticipated Completion Date: July 2023

2022-001: Procurement Requirements Criteria: The Organization is required to establish a procurement policy in accordance with Uniform Guidance requirements, as specified in the compliance supplement. Condition: The Organization did not establish a procurement policy in accordance with Uniform Guidance 2 CFR 200.318 ? 200.327, as required for the major program. The Organization developed and implemented a policy during 2022 but it was not in effect for the whole organization for the entire year. Questioned costs: None Cause and Effect: By not having an updated procurement policy the Organization could expense funds that are not in accordance with the procurement policies established by Uniform Guidance. Corrective Plan: Midwest Food Bank NFP established a procurement policy in accordance with Uniform Guidance in 2022 to be fully implemented across the Organization with an effective date of January 1, 2023, led by Lisa Martin, CFO.