Corrective Action Plans

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2024 FINDING 2024-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: We implemented policies and procedures in accordance with Uniform Guidance 2 CFR 200.214. Statement of Concurrence and Responsible Persons: We concur with the auditors' finding. Aracelis Suárez Finance Director Implementation Date: Fiscal year 2024-2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION; GRANT No. AM-22-0072 Name of Contact Person: Stacey Amundson Corrective Action: When the Glasgow City Council adopts a revised purchasing policy, it will include the process to run a background check on the lowest responsible bidder of a project and check the SAM system for all required entities before awarding the contract. Proposed Completion Date: June 2025

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will ensure all new vendors will sign a suspension and debarment agreement prior to any payments being made. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: March 31, 2025 If the Cognizant or Oversight Agency has questions regarding this plan, please call Kelly Baldwin, Director of Finance at 410-239-3200.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ASSISTANCE LISTING No. 97.036 Name of Contact Person: Angela Newell, Administrative Officer Corrective Action: Carbon County is revising our procurement policy to include suspension and debarment requirements. This policy contemplates additional contract requirements to ensure both primary and subcontractors certify their eligibility for awards and/or subawards under Executive Orders 12549 and 12689, 2 CFR part 180, as well as, an internal check through the contract approval process via the Commissioners’ Office. Proposed Completion Date: July 2025

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to the SAM.gov website and CFR 200 guidelines. However, the department that applied for and accepted the grant failed to include CFR 200 Appendix II in the Professional Services Agreement and did not document the review of contractor status on SAM.gov. To address this, the City will provide targeted training for departments and staff involved in grants, focusing on compliance with grant policies, special provisions, and proper documentation of actions. Responsible Individual(s): Anna Guiles, Assistant Community Development Director Anticipated Completion Date: To be completed by 3/31/2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: City Manager Corrective Action: Employee training has been completed with all department heads to ensure future compliance with federal debarment requirements. We will do annual staff training on this and will work with our engineers to make sure they too are complying with the requirements. Proposed Completion Date: Ongoing

Corrective action plan: The Purchasing and Historically Underutilized Business Services (PHS) unit within PCS will provide additional mandatory training to staff responsible for vendor compliance checks. PHS will also revise the current Vendor Compliance Checks Procedure to include the evidence required to document compliance, including the run date. Furthermore, PHS management will establish a process for reviewing and approving the Form 1400 Procurement Checklist, regardless of the monetary value, to guarantee that vendor compliance checks are executed accurately and timely and in advance of covered transactions. Implementation dates: March 31, 2025 Responsible persons: Sonya Bebley, Director of Purchasing and Historically Underutilized Business Services, Procurement and Contract Services Department

Views of Responsible Officials and Planned Corrective Action: The Department will require all ARPA recipients provide a copy of their current/active registration with Sam.gov with each disbursement request. Moving forward, the Department will require any/all sub recipients with subrecipient monitoring under 2 CFR § 200.214 and subject to 2 CFR Part 180 to provide proof prior to execution of a grant agreement. Once implemented, we will provide staff training to understand what documentation is required prior to execution of an agreement and disbursement of funds. Independent testing of the established controls will be performed by Department Fiscal staff who have no role in the contracting process and this testing will be documented. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 Name of contact person: County Commissioners Corrective Action: The County Commissioners will work closely with the architects and engineers to ensure that this requirement is met for future projects. Proposed Completion Date: Immediately.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: Fallon County Commission/Clerk and Recorder Corrective Action: Procedures will be developed that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

The County will set up procedures to ensure reviews are performed that vendors are not excluded or disqualified.

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts for twelve contracts of a total of twenty-eight selections (43%) tested. Recommendation: We recommend that the Department enhance its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: Management disagrees with this finding. KDHE disagrees with this finding. KDHE has an established process in place which is documented in the Procurement Policies and Procedures manual that was provided as part of the audit request which shows that verification of suspension and debarment in the System for Award Management takes place prior to contractual agreements being fully executed as part of the agency’s established process. There is no requirement that KDHE is aware of that requires that the date of verification be documented. Action taken in response to finding: KDHE will make sure the date the verification was done is on the documentation. Name(s) of the contact person(s) responsible for corrective action: Kelly Chilson, Director of Procurement Planned completion date for corrective action plan: Immediately when new contracts are being created.

Management will review and clarify our procurement policies and procedures to ensure alignment with Uniform Guidance. We will clarify what documentation is sufficient to justify a lack of competition for purchases greater than the micro-purchase threshold. We will reinforce the need to document procurement decisions prior to entering into the procurement process and adequately retain the documentation by issuing targeted communication and presenting at various standing research administration staff meetings. Completion Date: December 31, 2025 University Contact and Responsible Party: Krystina J. Gross, Associate Vice Chancellor for Finance and Sponsored Projects, (314) 935-2073

Condition: There is no evidence the Road Commission performed a check to verify contractors were not suspended or debarred Planned Corrective Action: The Road Commission for Oakland County will establish formal policies around the internal review of contractors to ensure they are not suspended or debarred. In addition, the policy will ensure formal documentation of this review is maintained in the associated project. Contact person responsible for corrective action: Tim Becroft, Finance Director Anticipated Completion Date: 02/10/2025

The Town of Chelmsford, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY 2024-001 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The Town has implemented procedures to document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Town Management and Finance. Planned completion date for corrective action plan: Completed.

February 27, 2025 Finding 2024-001 U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: T9952110 Management's Response: Bothwell Regional Health Center will begin performing suspension and debarment checks on all vendors/contracts funded with grants in 2025. This process will be implemented in 2025 pending policy review processes. Bothwell Regional Health Center will start documenting reviews of suspension and debarment checks of vendors receiving Federal funds while onboarding new vendors and monitoring periodically throughout the year. Views of Responsible Officials and Corrective Action: Management agrees with the finding and management will implement a control process to ensure that suspension and debarment checks are performed on vendors/contracts funded with grants in 2025. Responsible Official: Steven Davis Chief Financial Officer Bothwell Regional Health

The following corrective actions have either been implemented or will be implemented to prevent recurrence: 1. Audit Documentation: For the identified contract, C/CAG obtained and affidavit from the vendor affirming their compliance with suspension and debarment requirements at the time of contract. C/CAG also confirmed that the consultant is currently not on the suspension and debarment list. This documentation has been shared with the auditors and added to the project file. 2. Quality Assurance: Staff confirmed that the C/CAG’s other federally funded contracts included the required suspension and debarment requirements. 3. Staff Training: All staff members that work or might work on federally funded activities have completed training on federal procurement requirements, including guidance on suspension and debarment protocols. This training references the necessity of conducting SAM.gov checks and obtaining certifications for all federalized contracts. The specific training was: "Navigating the Uniform Guidance: Procurement Standards," and it was conducted on December 18, 2024. The provider of the training was “Federal Grants Training.” Ten C/CAG staff attended the training, including staff in the following positions: Executive Director, Deputy Director, Stormwater Program Director, Transportation Systems Coordinator, Senior Program Specialist, and Program Specialist. Copied of the completion certificates are available upon request. To ensure ongoing compliance, all future staff working on federally funded activities will also complete training on relevant federal requirements as part of their onboarding or ongoing professional development. 4. Contract Template and Procurement Policy Update: C/CAG is in the process of updating its standard contract template and the Procurement Policy to include suspension and debarment language for all contracts, regardless of funding source. This proactive measure ensures compliance across all contracts, even if funding transitions from non-federal to federal sources. Starting in February 2025, all relevant new contracts will have suspension and debarment language. The new contract template is expected to take effect beginning in April of 2025, and all contracts signed from that time onward will use the updated template. Furthermore, C/CAG will continue to review and update its contracts and policies regularly to ensure compliance with evolving regulations and standards. 5. Verification Procedures: Moving forward, C/CAG will: o Require vendors to provide a certification of compliance with suspension and debarment requirements before executing any agreement. o Conduct SAM.gov checks for all federally funded contracts.

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

2024-007 – Procurement, Suspension and Debarment. Auditor Description of Condition and Effect. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Auditor Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. Corrective Action. College to create a procedure that will require a vendor search to determine if vendors are listed as suspended or debarred, or otherwise excluded from participating, before engaging with them. In addition, the college will remind employees involved in purchasing that they must follow the college’s threshold regarding amounts of purchases. Responsible Party. Connie Stewart, SR VP & COO will create and implement new policy. Anticipated Completion Date. As soon as practicable but no later than February 28, 2025.

Type of Finding : Significant Deficiency Over Compliance with Procurement and Suspension Debarment Delta County Joint School District No. 50J had the following regarding internal controls in Nutritional Services: The District did not properly procure one vendor within the Child Nutritional Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516. Delta County Joint School District No. 50J concurs with finding 2024-001 and will implement the following corrective steps: Additional procedures have been put in place, and documentation will be maintained for purchases to satisfy Procurement and Debarment requirements.

Bear River Association of Governments (BRAG) will update internal policies to assign a member of the management team to check the federal system for suspension or disbarment for any checks written to vendors over $25,000 related to BRAG grants that involve federal funding.

Finding 2024-001: Suspension and Debarment – Material Weakness in Internal Control Over Compliance Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Views of Responsible Officials and Planned Corrective Actions: The Organization's ability to perform the current manual control for suspension and debarment was impacted by the sustained high level of activity. In December 2024, the Organization developed and implemented a Robotic Process Automation (RPA) tool designed to identify new vendors added to the accounts payable system. This tool then searches sam.gov for these vendors and sends an email with the results. Utilizing artificial intelligence, the tool also creates a service ticket for any suspect vendors that require manual research. Anticipated Completion Date: December 2024

Condition: The City could not provide evidence that it complied with 2 CFR 200.214, which states that nonfederal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. Planned Corrective Action: The city will ensure that all future contracts awarded under this program are in compliance and will have contractors sign to verify that they are in compliance. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2025