Corrective Action Plans

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

The Administrative Services Office will add an implementation process note to the College’s Administrative Policy 6.03 as well as in the Business Office’s Procedures Manual outlining a new Debarred and Suspended Parties Process. The new process will read as follows: To ensure that Central Wyoming College is not conducting business with vendors who have been suspended or debarred from conducting business with the Federal government, a department should check the vendor against the EPLS before creating a payment request or making a payment equal to or exceeding $25,000. The Principal Investigator (PI) or designee checks the vendor on www.sam.gov. The PI or designee will document the Suspension and Debarment verification by including a screen print of the Exclusions search in the grant file with a copy to the Grants Management Specialist and a copy to the Business Office with a W-9, if it’s a new vendor. For individuals or vendors that are found to be suspended or debarred, the PI or Grants Management Specialist will notify the Business Office to flag the vendor in Colleague alerting the person entering the voucher that they may not pay this vendor with Federal funds. Semi-annually the Grants Management Specialist will run a list of all vendors and employees paid from Federal funds over $25,000. Anticipated Completion Date: December 1, 2025 Contact Person(s): Willie Noseep, Vice President for Administrative Services

Reference Number: 2025-004 Description: Procurement Corrective Action Plan: The District will ensure that suspension and debarment certificates are obtained for all necessary vendors. If Certificates are not available, the District will search Sam.gov prior to doing business under a covered transaction. Contact Information: For additional information regarding this finding, please contact Ryan Bandt, Director of Business Services, at 920-675-1044.

Views of Responsible Officials and Planned Corrective Action: The Township has created a procedure to regularly check Sam.gov for suspension and debarment prior to issuing purchases orders or contracts and have it reviewed.

Significant Deficiency in Internal Control over Compliance and Compliance – Procurement, Suspension and Debarment Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746. Fiscal Year: July 1, 2023 – June 30, 2024 Recommendation: We recommend that management reinforce procedures to ensure that verification of procurement, suspension and debarment practices are performed and documented prior to entering into any covered transaction or subaward. This may include retaining screenshots from SAM.gov, signed certifications, contract clauses confirming compliance, and documentation of competitive pricing retained for records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The policies and procedures associated with this process will be improved per the audit recommendations and then training for all staff involved will be completed. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: December 31, 2025 If the third-party reviewer has questions regarding this plan, please call Simon Trowell, Chief Executive Officer at 215-563-0652

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Below $50k there will also be formal procedures with increasingly more oversight for purchases as they increase in cost. We will form and document a detailed procedure for issuing RFPs for PO amounts over $50k. We will review at least 3 proposals and once one is chosen, the vendor will be vetted before the proposal is accepted.

Management is not in agreement with this finding. The Organization has a policy in place to ensure that all contractors engaged with the Organization are being verified in advance of being engaged. This verification includes several security checks included verifying in required databases that they are not suspended or debarred. Senior management was not informed in time to produce the necessary documentation to the auditors. To ensure compliance in the future, management has revised its policy manual to include a formal checklist before signing any contracts for services.

In 2020, Intelligent Transportation Systems (ITS) was the sole bidder for the District’s camera project. The selected camera vendor was Hanwha Vision. In 2023, ITS was sold. At the time of the sale, ITS had only completed a portion of the project. On February 22, 2023, the District extended the GIS contract of Environmental Science Services (ES2) through February 17, 2024, and transferred the remaining scope of the camera project from ITS to ES2. The camera technology was integrated into the GIS environment for the District. The remaining cameras to be installed were purchased under the ES2 2023 contract at a lower price than in the ITS 2020 awarded low bid. In retrospect, the District should have rebid the project because the cameras were funded under the Port Security Grant Program (PSGP). The oversight was mainly caused by the transition of District executive personnel starting in 2023. Though this was an oversight, the camera technology integrated in the GIS environment increases the Port’s safety and security posture. The District now adheres to its newly adopted Procurement Policy to prevent recurrence. Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds to ensure full compliance with federal procurement standards, Louisiana Bid Law, Procurement Code, contract management protocols, and grant administration requirements: • The District is reviewing and updating its procurement policies to ensure alignment with federal procurement regulations, including those outlined in 2 CFR Part 200 (Uniform Guidance). All PSGP-funded procurements will be subject to competitive bidding procedures, proper documentation, and approval protocols to ensure transparency and compliance. • The District has reinforced its procurement procedures to ensure that all purchases exceeding $60,000 are formally advertised and awarded in accordance with Louisiana Revised Statute 38:2212. For purchases between $30,000 and $60,000, staff are required to obtain, document, and retain at least three competitive quotes in the procurement file. No significant purchases will be made without prior approval from the governing authority. • Formal procedures have been implemented to ensure that all PSGP-related contracts are properly executed, monitored, and supported by complete documentation. These procedures will includes verification of scope, deliverables, and performance timelines prior to payment authorization along with any solicitations, bids or quotes, evaluations, approvals, and any supporting documentation required by law and internal policy.• The District has designated a marine inspector to oversee PSGP grant activities, including expenditure review, documentation standards, and reporting requirements. All disbursements will be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance. • Management is actively consulting with FEMA to assess the allowability of identified questioned costs. The District will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in procurement, contract management, and grant administration. These sessions will cover federal compliance requirements, internal control

We have changed the process so all contracts are collected at the SAU central office to ensure completeness.

Corrective Action Plan (Unaudited): To address this finding and prevent future recurrence, the City will implement the following corrective actions: 1) Updated grant management policies and procedures: The new grant management policy and procedures will explicitly cover informal procurements funded with federal dollars, highlighting the need for compliance with the Uniform Guidance and requiring suspension and debarment checks regardless of contract type. 2) Procurement controls: Procurement will continue conducting SAM.gov checks for all federally-funded vendors, including any payments that hit grant funds within the financial system, and save documentation in the contract files. 3) Training: Annual training will emphasize the uniform guidance, specifically suspension and debarment rules, with added focus on informal procurements and direct payments without a contract. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026

Corrective Action Plan (Unaudited): To address this finding and prevent future recurrence, the City will implement the following corrective actions: 1) Updated grant management policies and procedures: The new grant management policy and procedures will explicitly cover informal procurements funded with federal dollars, highlighting the need for compliance with the Uniform Guidance and requiring suspension and debarment checks regardless of contract type. 2) Procurement controls: Procurement will continue conducting SAM.gov checks for all federally-funded vendors, including any payments that hit grant funds within the financial system, and save documentation in the contract files. 3) Training: Annual training will emphasize the uniform guidance, specifically suspension and debarment rules, with added focus on informal procurements and direct payments without a contract. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.

Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency and accountability in our operations. Managements Response to Audit Finding on inadequate recording of procurement history or justification: 1. Review and Update Procurement Policies:  We will conduct a thorough review of our current procurement policies and procedures to identify any gaps or areas requiring improvement.  Updates will be made to ensure that our procurement policies align with federal regulations, including those related to suspension and debarment. 2. Training for Staff:  We will provide comprehensive training for all staff involved in the procurement process to ensure they understand the updated policies and the importance of maintaining proper records.  Training will include guidance on documentation requirements, vendor selection criteria, and compliance with federal regulations. 3. Implementation of Record-Keeping System:  We will implement a centralized, secure, and user-friendly record-keeping system to document all procurement activities.  This system will include templates and checklists to guide staff in capturing all necessary information, including vendor selection, bid evaluations, contract awards, and verification of suspension and debarment status. 4. Regular Monitoring and Audits:  We will establish a schedule for regular internal audits of the procurement process to ensure ongoing compliance and to identify any potential issues promptly.  Findings from these audits will be reviewed by senior management, and corrective actions will be taken as needed. 5. Vendor Verification:  We will enhance our procedures for verifying the suspension and debarment status of potential vendors before awarding contracts.  This verification process will be documented and retained as part of the procurement records. Conclusion: FASEB is committed to addressing the findings related to procurement and suspension and debarment. We believe that the steps outlined in our corrective action plan will ensure compliance with Federal regulations and enhance the integrity and transparency of our procurement process. We appreciate the opportunity to improve our practices and will provide updates on our progress as requested.

The National Conference of State Historic Preservation Officers respectfully submit the following corrective action plan for the year ended December 31, 2024 Name and address of independent public accounting firm: CBIZ 1899 L Street, NW, Suite 850 Washington, DC 20036 Audit Period: January 01, 2024 to December 31, 2024 The findings from the Schedule of Finding for the year ending December 31,2024, are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding No. 2024-001 Revenue Recognition – Significant Deficiency in Internal Control over Financial Reporting: The finding was that NCSHPO provided a trial balance and SEFA that omitted indirect cost rates on accrued direct expenditures through December 31, 2024. Contacts for Corrective Action: Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465 Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465 The NCSHPO only recognized the direct costs as revenue for the period ending 12/31/24 not considering that the indirect cost rate should be accrued as revenue also thus causing the SEFA to not balance with the Trial Balance at the end of the year. NCSHPO agreed with CBIZ that the indirect costs should be recognized. The NCSHPO will begin a new internal control procedure to recognize the indirect costs as revenue to include on the SEFA schedule monthly beginning July 1, 2025. The SEFA and the Trial Balance will be reconciled for each job report. When Accounts Receivable (1120-000-0000), Revenue (4700-104-XXXX) and Administration fee/Indirect costs (4420-000-0000) are reconciled, then the SEFA, the Trial balance and the journal entry transaction(s) to recognize revenue will be given to the Executive Director to review and approve to be entered into the General Ledger. Implementation date: 07-01-2025 Finding No. 2024-002 Procurement – Significant Deficiency in Internal Control Over Compliance RE: Federal Award Identification Numbers P17AC00528 and P22AM01146 The finding was that NCSHPO failed to perform the required search of vendors per Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Section 200.213. NCSHPO agreed with CBIZ that we did not do a search for suspension and debarment in SAM for any of the vendors and that it was not included in our Procurement Policy. Contacts for Corrective Action: Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465 Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465 The NCSHPO updated the Procurement Policy to include a section for Suspension and Debarment. NCSHPO then used SAM to obtain the proper documentation to include in each respective vendor’s file. The NCSHPO will implement the new procedure to do a search in SAM.gov for every vendor it selects to do business with under the Cooperative Agreement and continue to do the search annually. Below is the new policy that is included in NCSHPO’s Procurement Section: Suspension and Debarment: NCSHPO verifies that the vendor or subrecipient with whom NCSHPO intends to do business is not excluded or disqualified in accordance with 2 C.F.R. Part 200, Appendix II (1) and 2 C.F.R. §§ 180.220 and 180.300. Before final selection, the Business Manager or the Special Projects Manager will perform a search on the General Services Administration Excluded Parties List System (EPLS) (http://www.sam.gov). Results of the screenings should be printed and placed in the procurement file. Suspension and debarment checks will be updated annually and will remain documented in the procurement file in line with NCSHPO’s document retention policy. The ED ensures this is completed during inspection and approval of procurement. Implementation date: 04/30/2025

Views of Responsible Officials: HIAS management accepts this comment and is finalizing a new comprehensive policy on the vetting of contractors and other third parties.

The American Immunization Registry Association (AIRA) respectfully submits the following corrective action plan for the year ending September 30, 2024. Independent public accounting firm: HAN GROUP, LLC, Washington, DC Audit period: Year ending September 30, 2024 The finding from the year ending September 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2024-001 – Procurement, Suspension and Debarment. Audit Recommendation – Strengthen internal controls over procurement documentation by: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. Management Response – AIRA acknowledges the finding and will implement the following: 1. Procurement Checklist: A standardized procurement checklist will be developed and required for all federally funded procurements. This checklist will help ensure consistent documentation practices and that all necessary procurement steps and compliance elements are completed and retained. Documentation of the completed checklist will be retained in the procurement file. 2. Vendor Eligibility Verification: A formal review process will be established to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. Documentation of the eligibility check will be retained in the procurement file. 3. Staff Training: Targeted training sessions will be conducted on a recurring basis for all staff involved in the procurement process. These trainings will reinforce federal compliance requirements, including proper documentation practices and suspension/debarment verification. Training completion will be tracked and documented. Implementation Timeline – As of March 18, 2025, AIRA has implemented a verification of vendor eligibility process using SAM.gov. The procurement checklist will be developed and implemented by April 30, 2025, and regular trainings will commence by May 31, 2025. We are committed to ensuring full compliance with federal procurement requirements. Please contact the Business and Operations Director at 202-552-0208 with any questions.

Planned Corrective Action: It is the policy of the Seattle Indian Health Board to retain documentation that a new vendor is not debarred from doing business with the federal government. In certain circumstances, due to the age of the vendor or other reasons, the documentation was not maintained. Management has engaged the accounts payable team to perform a review of all vendors accounts to assure all required documentation is on file and to continue this review on an annual basis. Name of Responsible Party: Brian Jonas., Controller Anticipated Completion Date: September 30, 2025

Views of Responsible Officials: Working diligently with NIH team to put policies and procedures in place to conduct the proper screenings for vendors, suppliers and consultants.

Based on the nature of this finding, it has been determined that this finding has been isolated to the Harris County Purchasing Department who has the oversight of issuing all purchase orders pertaining to Countywide grants. The Harris County Purchasing Department along with each sub-awarded County department will work to ensure the suspension and debarment requirements will be met as indicated in the Harris County Federal Procurement Policy Manual, adopted by Commissioners Court on March 8, 2022. The County Purchasing Agent shall work to implement the following controls to ensure all federal procurement requirements will be followed: • Obtain funding information from using departments to determine whether the procurement falls under federal funds. • If the procurement does fall under federal funds, a SAM.gov verification requirement will occur prior to processing the request for Commissioners court approval and/or approving a purchase order. • Require the purchase order requestor and/or purchasing agent to capture the date and website information to confirm the SAM.gov verification was performed in a timely manner. The County Purchasing Agent recognizes the importance of having debarment and suspension verifications included in the procurement file. The Harris County Purchasing Department is in the process of revising our internal procedure for Suspension and Debarments (SAMS) for contracts both below and above the $50,000 threshold. The existing internal procedure, last updated in 2018, is no longer adequate. By revising this procedure, we will ensure compliance with federal, state, and local procurement regulations.

Finding No. 2024-002: Procurement – Material Weakness in Internal Control Over Compliance Contact for Corrective Action: Jayson Tischler, Chief Operating Officer The Organization needed to sole source its architectural firm because it was mission-critical on a compressed timeline with the New Markets Tax Credit financing process. The Organization’s construction owner’s representative firm, D3 Development, LLC, undertook a market review that confirmed fair and reasonable pricing and service for the selected architectural services. The Organization then subsequently received a federal grant after the construction project began, which allowed the Organization to reimburse for architectural expenses. The Organization was able to reimburse through budget approval from HUD for those retroactive expenses, where competitive bidding had not been a requirement for the organization for any existing federal grants or awards. To ensure future compliance with federal procurement requirements, the Organization will revise its procurement policy to require a competitive bidding process, and proper documentation and record keeping of such, for all vendors eligible for reimbursement under federal programs. Additionally, the Organization will include suspension and debarment confirmation through the System for Award Management (SAM) in its procurement policy for all contractors. The Organization believes that these steps outlined above address this corrective action. Expected Completion Date: April 2025

SIGNIFICANT DEFICIENCY 2024-001 – The Organization did not have a process to determine if vendors were suspended or barred from receiving federal funds Auditor’s Recommendation:

It is recommended that The ONCAC develop and implement a comprehensive suspension and debarment procedure to review the eligibility of vendors before entering into contracts. Training should be provided to all relevant staff to ensure awareness and compliance with federal requirements. Additionally, periodic monitoring and internal audits should be conducted to ensure adherence to the established procedures. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and agrees with the recommendation. ONCAC will develop and implement a formal suspension and debarment procedure within the next three months. Training sessions will be conducted for all procurement staff to ensure understanding and compliance with the new procedure. Furthermore, periodic reviews will be instituted to monitor adherence to these requirements and to prevent the recurrence of this issue.

Finding No. 2024-003: Procurement – Material Weakness in Internal Control Over Compliance Contact for Corrective Action: Matt Bergheiser, President The procurement policy for the organization will be updated to include a search of the suspension and debarment list as a first step towards compliance. UCD will implement and adhere to a strict protocol for verifying suspension and debarment status and conduct an open and competitive bidding process prior to awarding any contracts or subawards under federal programs as is outlined in our procurement policy document. All of the results of the process will be documented and submitted to the Finance department prior to the selection of a new vendor, in order to remain in compliance. Expected Completion Date: 3/31/2025

DCHS has reviewed its procedures and will ensure that awards are reported timely and accurately to FSRS and that documenation of compliance will be available for review.