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INDEPENDENT SCHOOL DISTRICT NO. 2190, YELLOW MEDICINE EASTLocal Government

EIN: 416004911

UEI: MXCVJGF3JPJ8

Audited by: Hoffman & Brobst PLLP

Oversight agency: 84 [Department of Education]

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Data as of September 2, 2026

INDEPENDENT SCHOOL DISTRICT NO. 2190, YELLOW MEDICINE EAST4 audit years8 findings6 repeat
4
Audit Years
8
Total Findings
6
Repeat Findings
$1M
Federal Awards Expended (FY 2024)

FY 2024-06-30

$1,004,007 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 11, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 11, 2025 (453 days ago).

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2024-003
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2023-004

The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

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Full finding narrative

Criteria: The District should have control procedures in place to ensure that compliance requirements applicable to federal programs are met. This finding was reported in the previous year as number 2023- 004. Condition: The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

Corrective Action Plan

Auditor Recommendation We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the establishment of appropriate controls to ensure compliance in regard to federal program compliance requirements. 3. Official Responsible for Ensuring CAP Rich Schneider is the official responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan.

Prior Finding References

2023-004

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2024-004
Procurement & Suspension/Debarment
MODIFIED OPINIONREPEAT OF 2023-005

The District did not implement a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards prior to adopting documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Effect: The District did not meet federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327, until November 13, 2023. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Recommendation: We recommend that the District continue to follow the written procurement policy adopted on November 13, 2023, to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

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Full finding narrative

Criteria: Per Title 2 U.S. Code of Federal Regulations §200.318, the District must have and use documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. This finding was reported in the previous year as number 2023-005. Condition: The District did not implement a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards prior to adopting documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Effect: The District did not meet federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327, until November 13, 2023. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until November 13, 2023. Recommendation: We recommend that the District continue to follow the written procurement policy adopted on November 13, 2023, to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

Corrective Action Plan

Auditor Recommendation We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) ensured the adoption of a written procurement policy on November 13, 2023, to ensure that the federal program compliance requirements are being followed. 3. Official Responsible for Ensuring CAP Rich Schneider was the official responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan was implemented on November 13, 2023. 5. Plan to Monitor Completion of CAP Rich Schneider monitored this plan.

Prior Finding References

2023-005

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FY 2023-06-30

$1,238,690 federal awards expended

FAC accepted this audit on December 13, 2023 — management decision was due June 13, 2024.

2023-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2022-002

The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. This finding was reported in the previous year as number 2022-002. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022.

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Full finding narrative

Criteria: The District should have control procedures in place to ensure that compliance requirements applicable to federal programs are met. Condition: The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. This finding was reported in the previous year as number 2022-002. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022.

Corrective Action Plan

Auditor Recommendation We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the establishment of appropriate controls to ensure compliance in regard to federal program compliance requirements. 3. Official Responsible for Insuring CAP Rich Schneider is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan.

Prior Finding References

2022-002

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2023-005
Procurement & Suspension/Debarment
MODIFIED OPINIONREPEAT OF 2022-003

The District did not implement a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022. This finding was reported in the previous year as number 2022-003. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards prior to adopting documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Effect: The District did not meet federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327, until December 12, 2022. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022. Recommendation: We recommend that the District continue to follow the written procurement policy adopted on December 12, 2022, to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

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Full finding narrative

Criteria: Per Title 2 U.S. Code of Federal Regulations §200.318, the District must have and use documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Condition: The District did not implement a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022. This finding was reported in the previous year as number 2022-003. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards prior to adopting documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327. Effect: The District did not meet federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327, until December 12, 2022. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations §200.317 through §200.327 until December 12, 2022. Recommendation: We recommend that the District continue to follow the written procurement policy adopted on December 12, 2022, to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor’s recommendations will be adopted.

Corrective Action Plan

Auditor Recommendation We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) ensured the adoption of a written procurement policy on December 12, 2022, to ensure that the federal program compliance requirements are being followed. 3. Official Responsible for Insuring CAP Rich Schneider was the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan was implemented on December 12, 2022. 5. Plan to Monitor Completion of CAP Rich Schneider monitored this plan.

Prior Finding References

2022-003

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FY 2022-06-30

$1,654,121 federal awards expended

FAC accepted this audit on December 18, 2022 — management decision was due June 18, 2023.

2022-002
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2021-001

The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. This finding was reported in the previous year as number 2021-001. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

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Full finding narrative

2022-002 Controls over Compliance of Federal Programs Criteria: The District should have control procedures in place to ensure that compliance requirements applicable to federal programs are met. Condition: The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. This finding was reported in the previous year as number 2021-001. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

Corrective Action Plan

2022-002 Controls over Compliance of Federal Programs Auditor Recommendation We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the establishment of appropriate controls to ensure compliance in regard to federal program compliance requirements. 3. Official Responsible for Insuring CAP Rich Schneider is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan.

Prior Finding References

2021-001

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2022-003
Procurement & Suspension/Debarment
MODIFIED OPINIONREPEAT OF 2021-002

The District has not implemented a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. This finding was reported in the previous year as number 2021-002. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards without documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Effect: The District is not meeting federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

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Full finding narrative

2022-003 Procurement Policy Criteria: Per Title 2 U.S. Code of Federal Regulations ?200.318, the District must have and use documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Condition: The District has not implemented a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. This finding was reported in the previous year as number 2021-002. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards without documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Effect: The District is not meeting federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

Corrective Action Plan

2022-003 Procurement Policy Auditor Recommendation We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the adoption of a written procurement policy to ensure that the federal program compliance requirements are being followed. 3. Official Responsible for Insuring CAP Rich Schneider is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan.

Prior Finding References

2021-002

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FY 2021-06-30

$1,072,168 federal awards expended

FAC accepted this audit on December 15, 2021 — management decision was due June 15, 2022.

2021-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

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2021-001 Controls over Compliance of Federal Programs Criteria: The District should have control procedures in place to ensure that compliance requirements applicable to federal programs are met. Condition: The District has established internal controls over compliance for the major federal programs; however, these controls failed in regard to establishing documented procurement procedures in accordance with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: During our examination of compliance with federal programs, we noted one instance of internal controls not preventing noncompliance with the requirements of the federal programs. Effect: The District did not comply with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not establish documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

Corrective Action Plan

2021-001 Controls over Compliance of Federal Programs Auditor Recommendation We recommend that the District establish appropriate controls to ensure compliance in regard to the compliance requirements of federal programs. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the establishment of appropriate controls to ensure compliance in regard to federal program compliance requirements. 3. Official Responsible for Insuring CAP Rich Schneider is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan

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2021-002
Procurement & Suspension/Debarment
MODIFIED OPINION

The District has not implemented a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards without documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Effect: The District is not meeting federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

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Full finding narrative

2021-002 Procurement Policy Criteria: Per Title 2 U.S. Code of Federal Regulations ?200.318, the District must have and use documented procurement procedures for the acquisition of property or services consistent with State, local, and tribal laws and regulations and the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Condition: The District has not implemented a procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Questioned Costs: There are no questioned costs associated with this finding. Context: The District acquired property and services with federal awards without documented procurement procedures in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Effect: The District is not meeting federal regulations pertaining to the requirement to have and use documented procurement procedures for the acquisition of property or services consistent with the standards of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Cause: The District did not implement a written procurement policy in accordance with the requirements of Title 2 U.S. Code of Federal Regulations ?200.317 through ?200.327. Recommendation: We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and the auditor?s recommendations will be adopted.

Corrective Action Plan

2021-002 Procurement Policy Auditor Recommendation We recommend that the District adopt a written procurement policy to ensure that the federal program compliance requirements are being followed. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Rich Schneider (Superintendent) will ensure the adoption of a written procurement policy to ensure that the federal program compliance requirements are being followed. 3. Official Responsible for Insuring CAP Rich Schneider is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented immediately. 5. Plan to Monitor Completion of CAP Rich Schneider will be monitoring this plan.

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