Corrective Action Plans

Finding 2024-004: PROCUREMENT, SUSPENSION, AND DEBARMENT Description of Finding: For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. Statement of Concurrence or NonConcurrence: Identified 4 instances in which sufficient documentation was not maintained to support the procurement of a vendor. Corrective Action: Three of the vendors have services that will be put out to bid (landscaping, contract repairs and hazardous cleanup). The third service provided is generally of an emergency nature (plumbing) as we have a licensed plumber on staff. NBHA will make sure we have secured verbal quotes for each occurrence before obligating the vendor. Name of Contact Person: Tracy Blackwell Projected Completion Date: 09/30/2025

Boston Public Schools has revised its’ eligibility record keeping process to ensure that records are accurate and complete. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Procurement, Suspension and Debarment Description of Findging: For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. Auditors identified 3 instances in which sufficient documentation was not maintained to support the procurement of a vendor. Statement of Concurrence or NonConcurrence: There were 3 instances in which sufficient documentation was not maintained to support the procurement of a vendor. The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. Corrective Action: Two of the vendors have services that will be put out to bid (landscaping and hazardous cleanup). The third service provided is generally of an emergency nature (plumbing) as we have a licensed plumber on staff. NBHA will make sure we have secured verbal quotes for each occurrence before obligating the vendor. Tracy Blackwell

Boston Public Schools (BPS) has revised its’ consultation process to ensure it happens with fidelity and that records are properly stored. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

2022-004 Procurements, Suspension and Debarment Material Weakness/Material Non-compliance For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. Auditee?s Response and Planned Corrective Action: The two vendors identified were for T & T Complete Landscaping, LLC and One Stop Electronics. T&T Complete Landscaping: The total of $187,285 paid to the vendor consisted of three separate projects: REAC preparedness: $27,300 Asphalt paving: $68,500 General Landscaping (grass/brush) $91,485 While individual quotes were procured via meetings or phone calls, the NBHA cannot produce the alternative notes to document. One stop electronics: There were 9 procurements for a total of $53,422 paid to the vendor for appliances. Due to supply chain issues, availability in addition to price varied across major retailers of appliances. The logistics clerk called each major vendor to procure the necessary quantity and best price on each occasion, but did not retain record of competitive prices. Other vendors included Home Depot, Lowes and HD supply. NBHA will maintain a file of phone quotes for future documentation. NBHA will implement sufficient policies and procedures which provides for compliance with the Procurement, Suspension, and Debarment requirements of the Uniform Guidance. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Director of Operations, Logistics Clerk, Director of Finance - (860)225-3534

CORRECTIVE ACTION PLAN JANUARY 10, 2023 The Brevard Health Alliance, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Carr, Riggs, and Ingram, LLC 215 Baytree Drive Melbourne, FL 32940 Audit Period: Fiscal Year October 1, 2021 - September 30, 2022 The finding from the January 10, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. 2022-001 PROCUREMENT PROCEDURES COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For Homeless and Public Housing Primary Care) ? American Rescue Plan Act Assistance Listing Number: 93.224, Contract Numbers- H8F41284 Department of Health and Human Services (HHS) 2022 Funding Pursuant to 2 CFR ?200.1, Simplified Acquisition Threshold (?SAT?), acquisitions which exceed the SAT of $250,000 must use one of the following procurement methods: the sealed bid method, the competitive proposals method, or the noncompetitive proposal method (sole source). The Alliance did not utilize the sealed bid method or competitive proposals method for a purchase of computer hardware, which exceeded the $250,000 SAT. The Alliance?s procurement policy was not updated to be in compliance 2 CFR 200.1 until April 2022. This purchase began in fiscal year 2021, but the remaining items under the contract were procured in fiscal year 2022. Perspective: The purchase made at the beginning of the year was procured under the old purchasing policy. The policy was updated in April 2022, and the additional purchase exceeding the bid threshold made subsequent to the new purchasing policy was procured under a competitive process. Recommendation: The Alliance should continue to follow its updated procurement policy. Responsible Party: Shannon Wherry, Controller Corrective Action: Management updated the procurement policy April 2022 to comply with the provisions of 2 CFR ?200.1, 2 CFR ?200.67, and 2 CFR ?200.214. The updated policy has been implemented since this occurrence and will continue to be followed.