Corrective Action Plans

U.S. Department of Education 2023-002 IDEA Procurement, Suspension and Debarment Assistance Listing Nos. 84.027 and 84.173 Recommendation: CLA recommends that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented and communicated a process where all contracts and orders that exceed $25,000 require a Purchas Order to be created. The creation of the Purchase Order then alerts the Director of Procurement to perform the suspension and debarment checks. This will be done for all agreements exceeding $25,000, including repeat contracts. Name(s) of the contact person(s) responsible for corrective action: Jake Alverson, Director of Procurement Planned completion date for corrective action plan: 12/15/2023 If the U.S. Department of Education and Wisconsin Department of Public Instruction has questions regarding this plan, please call Sara Noah at (920)448-2200.

Child Nutrition Cluster - Assistance Listing nos. 10.553 and 10.555 Recommendation: CLA recommends the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transaction have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All food service vendors will be checked for suspension and debarment on the Sam.gov website. Name(s) of the contact person(s) responsible for corrective action: Morgan Mueller, Bookkeeper Planned completion date for corrective action plan: July 1st 2023

Procedures will be updated to include verification that a vendor has not been suspended or debarred. A record of this verification will be retained.

Finding 2023-002 Finding Summary: Suspension and Debarment Verification Procedures were not performed prior to entering into covered transactions. Responsible Individual: Robert Bryce Shields, District Attorney Corrective Action Plan: Pershing County District Attorney’s Office will enhance Internal Controls to ensure all contracts under Federal Awards contain the applicable provisions related to Suspension and Debarment or other procedures are performed to verify that the party is not suspended or debarred. Anticipated Date of Correction Action Plan: Corrected November 14, 2023

Finding Number: 2023-001 Condition: The City had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Planned Corrective Action: City Manager office staff has searched the State Procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future as part of Federal Grant Funding implementation staff will check vendors to make sure they are not debarred or suspended from federal funding awards. Contact person responsible for corrective action: Melissa Marsh, City Manager Anticipated Completion Date: 10/10/2023

County Judge/Executive’s Response: Staff will use purchase orders for all funds including disbursements from the American Rescue Plan Fund. However, it should be noted that the information included on a purchase order including date, approval, general ledger account number, and amount were listed on each invoice included in this finding. The only item not included was the title “purchase order.” In addition, a separate ledger is maintained for this fund to monitor expenditures and appropriations. The current controls in place over federal funds provide the same assurance that expenditures will not exceed budget appropriations. This alternative procedure serves as an effective compensating control.

Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: Management was unaware of the Federal procurement process requiring suspension and debarment verification of vendors. Since becoming aware management has verified the good standing of both vendors in question. Management has updated its internal financial operating procedures to ensure future compliance with procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: Completed Contact: Stephen Marshall, Assistant Superintendent of Finance & Operations

The District agrees with the above condition. The District will implement a process to review vendors for suspension and debarment status.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Copies of all federal vendors’ SAM.gov Active Registration and status reports are kept on file; copies of all bids are kept with the winning bid’s invoice and supporting documentation. Name(s) of the contact person(s) responsible for corrective action: Pamela Tesch, Director of Business Services Planned completion date for corrective action plan: Ongoing

Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.

Recommendation: We recommend the District include contract language which ensures vendor are not suspended or debarred as well as utilize sam.gov to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Procedures will be updated to include verification that a vendor has not been suspended or debarred. A record of this verification will be retained.

Lincoln County (submitting Department and County Clerk’s Office) will verify through Sam.Gov that all claims submitted for payment using federal funds are not suspended, debarred, or excluded from receiving federal dollars prior to payment of the claim.

CORRECTIVE ACTION PLAN November 7, 2023 U.S. Department of Health and Human Services Boys and Girls Clubs of Kennebec Valley respectfully submits the following corrective action plan of the year ended June 30, 2023. Name and address of independent public accounting firm: One River CPAs 46 FirstPark Drive, Oakland, ME 04963 FINDING – FINANCIAL STATEMENT AUDIT 2023-001 – Material Weakness – Internal Control Material Weakness in Internal Control: Property and equipment adjustments were necessary to expense equipment below the capitalization policy. Additionally, depreciation expense was adjusted based on a revised useful life of the disposal of the old building as required for the financial statements to be fairly stated in accordance with U.S. Generally Accepted Accounting Principles (GAAP). Also, a gifts in kind adjustment was necessary to adjust for a duplicated item. The following errors were noted and corrected as a result of audit procedures: • Building Improvements was overstated by $122,249 • Net assets without donor restrictions were overstated by $258,704 • Revenues were understated by $252,387 • Expenses were understated by $115,932 Recommendation: Management should strengthen their review over purchases for compliance with their capitalization policy, review of useful lives of assets, and review the accuracy of recording gifts in kind revenue and expenses. Responsible Person for Corrective Action: Paula Burke, CFO Corrective Action to be Taken: CEO & CFO will review capitalization policy with the Finance Committee, and monthly during Finance Committee meetings review any expenditures over $10,000. CFO will review gifts in-kind with Resource Development Director prior to end of fiscal year adjustments. The anticipated completion date for this corrective action is January 2024 and June 2024. FINDING – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of the Treasury 2023-002 – 21.027 Coronavirus State and Local Fiscal Recovery Funds Significant Deficiency and Noncompliance: There was not a process in place to formally document the review of the contracted entity for suspension and debarment prior to entering into the agreement. Recommendation: Management should strengthen their processes, controls, and review over suspension, and debarment processes and ensure compliance with Uniform Administrative Requirements. Responsible Person for Corrective Action: Paula Burke, CFO Corrective Action to be Taken: Request construction manager to check suspension and debarment of all subcontractors prior to hire, if project has not already been started. The anticipated completion date for this corrective action is November 2, 2023. Per contact with Joe Lajoie (construction manager), he confirmed none of the contractors were on the debarment and suspension list. If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Paula Burke, CFO at 207-582-8458 or pburke@bgckv.org. Sincerely, Ingrid Stanchfield, Chief Executive Officer

It will be the practice of Antelope County to check vendor status with the SAMS/DUNS before any payments are made utilizing Federal funds. To further insure the funds are safely being utilized and spent, regular checks on the vendor status will be completed.

Holt County's first choice will be to obtain a certificate or an agreement with each entity stating they are in good standing.

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds- Suspension & Debarment Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, https://www .Sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: Ongoing Responsible Party:Dakota County Board of Commissioners: Robert J. Giese, Troy Launsby, Scott Love, Martin Hohenstein, and Brian VanBerkum.

Contanct Person: Vern R. McAdams, Business Manager Corrective Action Planned: The District has been careful to check for suspension / debarment for all orders placed with a purchase order or voucher on SAM.GOV that are coded to a federal grant. That process is documented on the individual purchase order or voucher before the order is approved by the BUsiness Manager and the order is placed. However, more purchases today are completed using a Distrct credit card. Before the Business Manager processes the monthly payment for credit card charges, he will check each transaction that is coded to a federal grant and check that vendor for suspension / debarment on SAM.GOV. Should a vendor be identified as suspended / debarred the transaction will be coded to a non-federal account or the item will be returned. We followed this process with the October billing cycle.

Corrective Action Planned: The County has discussed checking the SAM (System for Award Management formerly Excluded Parties Listing System (EPLS), which is maintained by the General Services Administration to ensure vendors are not suspended or debarred before entering a transaction. Anticipated Completion Date: Ongoing Responsible Party: Krista Nix, Deputy County Clerk

Finding 2023-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Corrective Action Planned: The County has put procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Completion Date: August 21, 2023 Responsible Party: Karla Zlatkovsky, County Clerk

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

Procurement and Suspension and Debarment: The College agrees with the finding and takes note of the previous corrective actions that did not fully resolve the issue. The College will update its Purchasing and Accounts Payable Policy to require SAM.gov verification prior to awarding contracts. The College will conduct mandatory procurement training to strengthen compliance with federal requirements.

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, verification of suspension and debarment status, and equitable distribution of micro- purchases. In addition, newly hired staff dedicated to Procurement and Accounts Payable have been onboarded to improve oversight and compliance. With these new systems, strengthened controls, and added staffing capacity, the College is now better positioned to maintain full compliance. Staff have been trained—and will continue to be trained twice a year—on procurement requirements and federal regulations to prevent recurrence of similar issues in future audits.

Corrective Action: The Department of Treasury will work closely with the Procurement, Grants, and Contracts program to monitor and enforce proper internal controls and reviews for vendors. Procurement and Accounts Payable teams have been notified of the required SAM.gov checks, and these documents will now be uploaded into Sage when a vendor is added or updated. Person(s) Responsible: Acting Treasurer, Controller, AP Manager and PG&C Director Estimated Completion Date: January 1, 2025

Views of responsible official and planned corrective actions: The Trust will review and enhance its current procedures to ensure that vendors who are debarred, suspended, or otherwise excluded from participation in Federal assistance programs or activities are restricted from receiving Federal awards, sub-awards, and contracts. The Trust will conduct internal audits at regular intervals to ensure the new procedures are being followed and that all required documentation is maintained properly in procurement files. The Trust's CEO and CFO, who joined the company in 2024, have been actively conducting internal reviews of the financials and ongoing projects. These officials are currently overseeing a course correction to ensure better alignment with the Trust's strategic goals. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: March 31, 2025

Finding 2022-018 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Management’s Response: Management will work with Procurement & departments to make sure debarment checks are completed. Views of Responsible Officials and Corrective Action: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS