Corrective Action Plans

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

Finding 2022-101 - Improve Internal Control over Reporting (Material Weakness) ? (Repeat Finding) FAL Numbers: 15.042 Program Titles: Indian School Equalization COVID-19 Indian School Equalization Condition and Context: The four quarterly reports were not filed within the 30 days required by the contract. Also, the Uniform Guidance requires the submission of a single audit reporting package to the Federal Audit Clearinghouse within nine months of the auditee?s fiscal year end. Recommendation: The auditors recommended that the School establish a system of monitoring for the filing of all required reporting and that the chief school administrator review the monitoring list on a regular basis consistent with the timing of report filings. Contact Name: Renee Ramirez, Business Manager Corrective Action Planned: HBCS will establish a monitoring system for the filing of all required reporting. Additionally, the principal will review the system on a regular basis to ensure the timely filing of all reports. Anticipated Completion Date: June 30, 2023

Management agrees with the finding. Due to vacancies experienced by the City of South Gate and the absence of a Director and Deputy Director of Administrative Services, management was not able to properly oversee the timely submission of the SF-425 financial reports for fiscal year ended June 30, 2022. Additionally, due to these vacancies, the late submission of these reports extended into the first two quarters of the following fiscal year. However, these vacant positions have since been filled and Management will ensure that all SF-425 financial reports are reviewed and submitted within 30 days after the reporting period end date.

Views of Responsible Officials and Planned Corrective Actions: We agree with the findings and recommendations of the auditor. The cause of this omission is due to the change in accounting and management personnel. The Organization has brought in an outside consultant who has set up a calendar to ensure these are not delayed going forward.

View of Responsible Officials and Planned Corrective Actions: FamilyForward was responsive and provided requested information to the awarding entity at each stage of the appropriation, single source determination, contracting, and payment process. FamilyForward relied upon the awarding entity?s single source determination that activities undertaken in our role as subrecipient were conducted in accordance with all required policies and procedures, including procurement. FamilyForward will implement procurement policies and procedures to ensure that we meet requirements of Uniform Grant Guidance in advance of soliciting or securing federal funds for projects.

MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https:sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.

Finding 2022-001: Significant deficiency in internal control over procurement. Summary: There was no documented evidence that a contractor was required to comply with the prevailing wage requirement of the Federal Award agreement in one contract under the Federal Award. Corrective Action Planned: Written policies and procedures regarding procurement and grant compliance will be updated and implemented to ensure compliance with procurement terms and conditions of Federal Awards. Anticipated Completion Date: By Sept 30, 2023. Name of Contact Person Responsible for Corrective Action: Tammy Rash, Administrative Services Director

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.

FINDING 2022-006 Contact Person Responsible for Corrective Action: Tyler C. Osenbaugh Contact Phone Number: 260-336-0217 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: Meal counts differed from the Meal Magic generated Z report and the Chartwells Profit and Loss statement. These meal counts are reconciled by dividing the a la carte purchases by $2.70 to equate to a meal served. Future Z reports will have the a la carte meal equivalents indicated. These figures will be reviewed and validated during the monthly meeting between School Food Authority and Food Service Director (Chartwells? Director of Dining Services). Anticipated Completion Date: April 2023

March 10, 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Community Action Partnership of Mercer County To whom it may concern: Views of Responsible Officials and Planned Corrective Actions: 2022-01 There is no disagreement with the audit finding regarding our procurement policies and the lack of documentation in the Weatherization file that was reviewed. The Organization will review the Procurement policies and make necessary adjustments to how we acquire services from contractors and what the thresholds are. We will also be reviewing our documentation policies in Weatherization and making the adjustments to what documents go into the consumer file. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: May 31, 2023 Respectfully Submitted, Michelle Clarke VP/CFO

COVID-19 Coronavirus State and Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the City implement controls to ensure its procurement policies and procedures are followed prior to entering into contracts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City acknowledges supply chain issues as a result of COVID-19 which limited purchasing options in one instance. The city will adjust business processes to provide additional review when making purchases to ensure compliance with the procurement policy and proper documentation is included for any exceptions. This will be incorporated immediately. Name of the contact person responsible for corrective action: Tiffany Hooten, Finance Director. Planned completion date for corrective action plan: July 18, 2023

Finding 2022-004 ? Significant Deficiency Assistance Listing: 21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Federal Grantor: Department of the Treasury Compliance Requirement: Procurement and Suspension and Debarment Condition: The District used a sole source authorization for the procurement of a Type-1 Fire Engine but a competitive bid process should have been used to comply with Uniform Guidance. Recommendation: We recommend the District work with FEMA to obtain written approval for the sole source procurement, which is one of the exceptions to noncompetitive procurements. Management Response and Corrective Action Plan: The District shall revise policies and procedures to incorporate the requirements in the Uniform Guidance in its sole source approval process when it comes to selecting and approving vendors for expenditures that relates to a federal grant. The District will also work with the awarding agency to ensure written approval are obtained for sole source purchases.

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.