Corrective Action Plans

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.

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