January 31, 2023 Caroline County School Board respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3106 Electric Road Roanoke, VA 24018 Audit period: June 30, 2022 The findings from the June 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-002: Procurement Policies and Procedures -COVID-19 Governor's Emergency Education Relief Fund - AL# 84.425C, COVID-19 Elementary and Secondary School Emergency Relief Fund - AL# 84.425D, and COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund-AL#84.425U Condition: The School Board adheres to and follows Virginia Public Procurement Act "VPPA" for procurement, however, under the requirements of Uniform Guidance, the School Board does not have complete, written procurement policies that are in compliance with the additional standards required by the Uniform Guidance (2 CFR Part 200). Criteria: Under the requirements in the Uniform Guidance, all entities are required to have written procurement policies that conform to applicable Federal laws and regulations and standards. The complete procurement standards are located at 2 CFR Part 200, Sections 317 through 326. Cause: The School Board does not have its own written procurement policies that conform to applicable Federal laws and regulations and standards. Effect: The lack of the School Board's own written policies under the specific requirements of Uniform Guidance could result in potential improper procurement using Federal funds. Questioned Costs: Not applicable Perspective Information: Not applicable Repeat Finding: Not applicable Recommendation: Management should update existing written procurement procedures to align with Uniform Guidance requirements for all purchases to be made with Federal funds. Views of Responsible Officials and Planned Corrective Action: CCPS School Board had approved updated procurement policies in July 2021 in response to the FY20 management letter comment on Uniform Guidance Policies. Upon receipt of the FY21 management letter, which included a repeat comment on Uniform Guidance Policies for the school board, CCPS staff contacted the previous auditors and shared with them the updated policies that the school board had previously updated and approved. The prior audit firm confirmed all required policies that pertained to the management letter comment had been updated. The new audit firm does not believe the school board policy updates that were approved previously were sufficient. Management has begun to review the existing written procurement policies and procedures and will complete another update to comply with the Uniform Guidance no later than May 2023. If the Federal Audit Clearinghouse has questions regarding this plan, please call Marcia Stevens, Chief Operations Officer at 804-633-5088 ext 1095. Sincerely yours, Marcia S. Stevens, CPA Chief Operations Officer