Corrective Action Plans

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The District will train food service administrative staff regarding adequate internal controls involving monthly downloads of the Department of Social and Health Services DSHS direct certifications, including training at least 2 administrative staff members in order to ensure compliance in the absen...
The District will train food service administrative staff regarding adequate internal controls involving monthly downloads of the Department of Social and Health Services DSHS direct certifications, including training at least 2 administrative staff members in order to ensure compliance in the absence of the primary staff member performing the necessary internal control. Should Supply Chain Assistance funds become available in the future, the District will retrain food service administrative staff regarding the tracking of qualifying food products to reconcile to the funds received, and complete that tracking prior to the end of the qualifying fiscal year.
View Audit 366821 Questioned Costs: $1
Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Corrine Schmid, 609 8th St Hoquiam, WA 98550, 360-538-3969 Corrective action the ...
Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Corrine Schmid, 609 8th St Hoquiam, WA 98550, 360-538-3969 Corrective action the auditee plans to take in response to the finding: Historically the City has complied with the federal suspension and debarment requirements through (1) ensuring each of its direct award and subrecipient contracts contain a clause or condition in the award contracts that states the contractor or subrecipient is not suspended or debarred, (2) requesting a certification to that effect, or (3) checking the SAM system to insure the contractor was not debarred or suspended. In this situation, the city procured equipment from a vendor under a "piggy-back" agreement under which debarment and suspension verification had been completed by another state agency. Regardless of the isolated nature of this incident, the City’s management remains committed to ensure this situation does not re-occur going forward, and as a result has or will be implementing the following corrective actions: • To the very limited extent disbarment/suspension language does not appear in contracts for goods or services being funded through federal funds, expenditures for all projects involving purchases of goods and services will have grant administration staff who will verify disbarment/suspension status prior to the entering into contracts or the disbursement of funds. • In the cases of piggy-back agreements, grant administration staff will verify disbarment/suspension requirements have been met prior to payments for goods or services being approved that are funded with federal funds. We thank the SAO staff for identifying this issue and bringing it to our attention. Anticipated date to complete the corrective action: September 2025
The staff has reviewed the Uniform Guidance requirements and has developed a standardized worksheet will be used for each reimbursement request, and all calculations will be reviewed by management prior to submission. All future correspondence with EDA regarding indirect costs will be documented in ...
The staff has reviewed the Uniform Guidance requirements and has developed a standardized worksheet will be used for each reimbursement request, and all calculations will be reviewed by management prior to submission. All future correspondence with EDA regarding indirect costs will be documented in writing. Implementation of the worksheet has commenced.
The Organization acknowledges the finding and appreciates the clarifications regarding the expiration of the temporary waiver of the “credit not otherwise available” requirements. Upon identification of this issue, we conducted a full review of all loans originated after June 30, 2022. As a result w...
The Organization acknowledges the finding and appreciates the clarifications regarding the expiration of the temporary waiver of the “credit not otherwise available” requirements. Upon identification of this issue, we conducted a full review of all loans originated after June 30, 2022. As a result we have retrofitted all loan files issued after the waiver expired to include appropriate documentation demonstrating that credit was not otherwise available on terms and conditions that would permit the completion or successful operation of the financed activity. Management has also implemented the following preventive measures going forward: • All new loan reports include a section on “credit not otherwise available” for loan committee members to review. • The Organization will annually review EDA guidance and policy changes to ensure that internal documentation practices remain aligned with current federal requirements.
Management’s Corrective Action Plan In response to finding 2024-001, management will improve the reporting timeliness of grant details by the identified timeframe. Management intends to implement a monitoring process to ensure compliance with the reporting requirements of the grants. This would incl...
Management’s Corrective Action Plan In response to finding 2024-001, management will improve the reporting timeliness of grant details by the identified timeframe. Management intends to implement a monitoring process to ensure compliance with the reporting requirements of the grants. This would include adherence to meeting the reporting timelines. Individual Responsible for Corrective Action Plan Nicole DuPont Director of Strategic Development & Grants (269) 986-0077 Anticipated Completion Date: October 1, 2025
Planned Corrective Action: Current policy and procedure in place will be followed. The grant accountant and food compliance officer will review Summer Food Service Program sites and reimbursements prior to the completion of the SFSP program period each year.
Planned Corrective Action: Current policy and procedure in place will be followed. The grant accountant and food compliance officer will review Summer Food Service Program sites and reimbursements prior to the completion of the SFSP program period each year.
View Audit 366736 Questioned Costs: $1
Criteria: Federal and state grant agreements typically require recipients to maintain effective internal controls over financial reporting. These include accurate and timely submission of required reports; proper documentation and retention of supporting records and review and approval processes to ...
Criteria: Federal and state grant agreements typically require recipients to maintain effective internal controls over financial reporting. These include accurate and timely submission of required reports; proper documentation and retention of supporting records and review and approval processes to ensure compliance and accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment: To prevent miscoding of expenses, we implemented a change in the prior fiscal year to allocate all CACFP-related expenses to a distinct program code. This ensures that CACFP costs are tracked independently and not charged to direct programs. Root Cause Reconciliation of the reimbursement from USDA can vary on the reimbursement of the cost of food. Where there is less cost than reimbursement we are reconciling the overage to staff wages of kitchen staff and supplies for the kitchen at the end of the year instead of monthly. Action Taken Reconciliation of the monthly reimbursement amount from CACFP to the food expenses will be reviewed each month by the 10th (for the following month) and reconciliation to the appropriate programs will be journal entries and included in the monthly review of revenue and expenses.
Corrective Action: 4-C has implemented a procedure for reviewing and approving all financial reports to external entities. Responsible for Corrective Action: Management Team Anticipated Completion Date: 8/26/2025
Corrective Action: 4-C has implemented a procedure for reviewing and approving all financial reports to external entities. Responsible for Corrective Action: Management Team Anticipated Completion Date: 8/26/2025
Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends for the Organization to place emphasis on stronger controls around the timely filing of required reports, such as retaining a monthly checklist of required re...
Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends for the Organization to place emphasis on stronger controls around the timely filing of required reports, such as retaining a monthly checklist of required reconciliations and reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previous corrective actions were completed in October 2024 following FY 2022 & 2023 Audits, including creating a calendar of required reconciliations and reports for all agreements. We also updated our procedure for review, approval, and documentation of Federal Financial Reports. We intend to add an additional and stronger control by adding performance and financial report schedules as part of our internal project software (Asana). Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/1/2025
Health Resources and Services Administration Mary Zelazny, Finger Lakes Migrant Health Care Project, Inc.’s CEO respectfully submits the following corrective action plan for the year ended December 31, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 20...
Health Resources and Services Administration Mary Zelazny, Finger Lakes Migrant Health Care Project, Inc.’s CEO respectfully submits the following corrective action plan for the year ended December 31, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2024 Item 2024-001 – Procurement, Suspension and Debarment (Material Weakness) During our audit, we noted that there is no evidence that any exclusion search was conducted in 2024 for all sample employees tested. Recommendation We recommend that the Project train its employees in relation to their policies and procedures on conducting exclusion screening and on proper documentation thereof. Action Taken Management agrees with the finding. As of the effectivity date below, procedures have been revised and personnel have been trained to help ensure the accuracy, completeness and timeliness of exclusion searches. The Compliance department has added periodic internal auditing of the process to their calendar. Effective Date: January 1, 2025
FINDING 2024-001 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Angela Eck Contact Phone Number and Email Address: 260-868-5200, clerktreasurer@cityofbutler.in.gov Views of Responsible Officia...
FINDING 2024-001 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Angela Eck Contact Phone Number and Email Address: 260-868-5200, clerktreasurer@cityofbutler.in.gov Views of Responsible Officials: “We concur with the finding.” Explanation and Reasons for Disagreement: Not applicable Description of Corrective Action Plan: The Clerk-Treasurer will meet with the Mayor and Department Heads to ensure that they provide the Clerk- Treasurer’s Office time to verify that a potential vendor or contractor is not suspended, debarred or otherwise excluded from receiving federal funds. The Clerk-Treasurer will also create a form for this purpose and follow it for all contracts or purchases that are over $25,000. This will apply to all future federal projects. Anticipated Completion Date: The Clerk-Treasurer will meet with the Mayor and Department Heads before October 1, 2025. A form will be created by November 1, 2025.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pacific Transit System January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the Transit for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (C...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pacific Transit System January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the Transit for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The Transit did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of Transit contact person: Mike Williams, Clerk of the Board PO Box 489, Raymond, WA 98577 (360) 875-9418 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). Pacific Transit will confirm all vendors selected for purchases of $25,000 or more are registered with SAM.gov and are not suspended or debarred from doing business with the federal government. Anticipated date to complete the corrective action: September 17, 2025
Federal program title: Community Development Block Grant – CFDA 14.228 Condition: During our test of the reporting requirements for Community Development Block Grant program, we determined that the County did not submit the required reports under Reporting of the Compliance Supplement. Recommendatio...
Federal program title: Community Development Block Grant – CFDA 14.228 Condition: During our test of the reporting requirements for Community Development Block Grant program, we determined that the County did not submit the required reports under Reporting of the Compliance Supplement. Recommendation: CLA recommends the County develop procedures, such as a reporting checklist to ensure that reporting requirements are tracked and met. Additionally, CLA recommends that the County perform cross training with employees to ensure that knowledge is shared among the team members. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for corrective action plan: Completed and on-going
Federal program title: Home Partnership Investment Program, and Local Assistance and Tribal Consistency Fund program CFDA 14.239, 21.032 Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This pr...
Federal program title: Home Partnership Investment Program, and Local Assistance and Tribal Consistency Fund program CFDA 14.239, 21.032 Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This process should ensure that key documents are securely stored, easily accessible, and periodically reviewed to support ongoing compliance with grant requirements. Additionally, the County should work with granting agencies to obtain copies of any missing agreements and perform a comprehensive review to identify and address any outstanding compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Completed and on-going.
Federal program title - U.S. Department of Housing and Urban Development – 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is p...
Federal program title - U.S. Department of Housing and Urban Development – 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the HOME grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Completed and on-going.
View Audit 366553 Questioned Costs: $1
Federal program title – Community Development Block Grant Recommendation: CLA recommends the County develop procedures, such as a checklist to ensure that special tests and provision requirements are tracked and met. Additionally, CLA recommends that the County perform cross training with employees ...
Federal program title – Community Development Block Grant Recommendation: CLA recommends the County develop procedures, such as a checklist to ensure that special tests and provision requirements are tracked and met. Additionally, CLA recommends that the County perform cross training with employees to ensure that knowledge is shared among the team members. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequate close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Completed and on-going.
View Audit 366553 Questioned Costs: $1
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is perf...
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the CDBG grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for correcting action plan: Completed and on-going.
View Audit 366553 Questioned Costs: $1
FINDING 2024-003 (prior finding audit number 2023-002) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in...
FINDING 2024-003 (prior finding audit number 2023-002) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: One person will complete the report and another will sign off on a full review. Anticipated Completion Date: April 1, 2026 (based on due date of the next report)
FINDING 2024-002 (prior finding audit number 2023-001) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@mont...
FINDING 2024-002 (prior finding audit number 2023-001) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A new policy was adopted after the previous audit to ensure proper language regarding suspension and debarment is included in every contract. Because the contracts are outside of Auditor control, the Auditor is requesting county management to get an amendment for the vendor in question, Indiana American Water. Anticipated Completion Date: 08/31/2025
FFT will monitor its subcontractor for compliance in the future.
FFT will monitor its subcontractor for compliance in the future.
FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Katherine Adamson Contact Phone Number and Email Address: 574-223-2912 auditor@co.fulton.in.us View of Responsible Officials: We...
FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Katherine Adamson Contact Phone Number and Email Address: 574-223-2912 auditor@co.fulton.in.us View of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This grant is fully expended; however the Auditor will work with the County Attorney and Commissioners to create the necessary policies and procedures for the County related to Suspension and Debarment of other grant funds. Anticipated Completion Date: December 31, 2025
WEST MICHIGAN FOOD PROCESSING ASSOCIATION CORRECTIVE ACTION PLAN DECEMBER 31, 2024 West Michigan Food Processing Association respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912...
WEST MICHIGAN FOOD PROCESSING ASSOCIATION CORRECTIVE ACTION PLAN DECEMBER 31, 2024 West Michigan Food Processing Association respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit period: Year ended December 31, 2024. District Contact Person: Marty Gerencer, Contracted Executive Director The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding: Federal Awards and Questioned Cost Finding 2024-01 Recommendation: We recommend that West Michigan Food Processing Association develop and implement comprehensive written policies and procedures to address the requirements of the Uniform Guidance. These should be tailored to the Association’s structure and operations and cover all applicable federal compliance areas. Management should also establish a process to periodically review and update these documents to ensure continued compliance. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future. Finding: Financial Statement Audit Finding 2024-02 Recommendation: We recommend implementing a compensating control to mitigate this risk, such as: ➢ Requiring documented approval by a board member or other authorized individual prior to processingdisbursements, or ➢ Providing a board member or finance committee member with view-only online access or automatedbank alerts to review all cleared transactions. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future.
FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Elmore Contact Phone Number and Email Address: 317-325-1315 Lelmore@greenfieldin.org Views of Responsible Officials: We con...
FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Elmore Contact Phone Number and Email Address: 317-325-1315 Lelmore@greenfieldin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Attorney will include this language in all our standard contracts and agreements to ensure all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or disbarred from participating in federal programs before entering a contract going forward. In addition, we will include a self-certification document for vendors to return to us as part of their bid packet and add to the checklist of requested items. The City Attorney and the Department Head, who is overseeing the project, will be responsible for confirming this document is received and the vendor is neither disbarred nor suspended. Anticipated Completion Date: Estimated to be in effect by September 30th, 2025, or earlier, following the completion of the exit interview and once the Audit Report has been posted on the SBOA website and we are free to openly discuss the audit findings.
Corrective action the auditee plans to take in response to the finding: CORRECTIVE ACTION PLAN: 7. Closely following the GUIDE FOR EDA CARES REVOLVING LOAN FUND SEMI-ANNUAL FINANCIAL REPORTING PROCESS FOR BFCOG-47289WA FOR EDA AWARD NUMBER 07-79-07622 document. To avoid errors in key lines, such as ...
Corrective action the auditee plans to take in response to the finding: CORRECTIVE ACTION PLAN: 7. Closely following the GUIDE FOR EDA CARES REVOLVING LOAN FUND SEMI-ANNUAL FINANCIAL REPORTING PROCESS FOR BFCOG-47289WA FOR EDA AWARD NUMBER 07-79-07622 document. To avoid errors in key lines, such as administrative expenses, RLF income earned during the fiscal year, and RLF income used for administrative costs for the fiscal year. 8. To further avoid discrepancies, BFCOG will move to a semi-annual administrative expense reimbursement cycle to align with the semi-annual reporting periods. By doing this instead of only once at year's end, we will lessen the chance of those expenses being missed in reporting. 9. The primary responsibilities of this process will be transferred to our Staff Accountant (A. Fernandez) and reviewed with the Authorized Representative/Lending Director (M. Holt). During this transfer of duties, our Staff Accountant and Authorized Representative/Lending Director will ensure adequate training for upcoming reporting cycles and proper internal and EDA-level review. 10. The EDA RLF Program Administrator provided guidance that there is no mechanism for correcting reports filed in error and that necessary corrections must be made when filing the 2025 Year-End Financial Report. 11. File the 2025 Year-End Financial Report accurately and on time and document the review and submission paper trail for future reference.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Montesano January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Montesano January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls in place to ensure compliance with federal procurement requirements. Name, address, and telephone of City contact person: Gretchen Sagen, CFO/Clerk 112 N Main Street Montesano, WA 98563 (360) 249-3021 Corrective action the auditee plans to take in response to the finding: To address this finding and strengthen documentation, the City is taking steps to: 1. Adopt a written City procurement policy that incorporates federal, state, and local thresholds and methods, consistent with 2 CFR 200.318–327; and 2. Update our standards of conduct to explicitly include all conflict-of-interest provisions required under federal regulations. These corrective actions will supplement the existing WSDOT oversight framework, provide auditors with clear reference points for internal controls, and ensure continued compliance with Uniform Guidance requirements. Anticipated date to complete the corrective action: October 2025
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