Corrective Action Plans

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors –– Houghton Mifflin-Harcourt ($509,919), Beaver Valley Intermediate Unit ($419,826), and Smart Solutions ($449,303). CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i), 200.320(a)(2)(i) and Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Saving Ourselves ($30,000), AGI Repair ($16,216), IXL ($19,218), Learning Systems Associates LLC ($25,425), AGC Education Inc. ($11,644), Apple ($163,505), Germ Solutions LLC ($160,070), Graham Security ($12,025), Curriculum Designers, Inc. ($27,875), RJ Rhodes Transit, Inc. ($24,845). CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

January 8, 2024 To whom it may concern: Southeast Conference (SEC) respectfully submits the following corrective action plan for the fiscal year ending 6/30/23. Our independent single federal audit was performed by Mertz, CPA & Advisor, 3140 Nowell Ave. Juneau, AK 99801. The following finding was discovered, and a corrective plan has been implemented: Finding number: ALN Title: ALN Number: Federal Award Year: Type of Finding: 23-0001 reporting Economic Adjustment Assistance (EDA BBB) 11.307 October 1, 2022, through September 30,2023 Deficiency in Internal Control and Noncompliance Condition and Context: This was the first year that SEC needed to implement the reporting requirement to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System {FSRS) for its subawards as required by FFATA guidance. SEC did not make timely, accurate reports as required. While this did not in any way compromise federal dollars, SEC has committed to the following corrective action plan and will continue its rigorous oversight of its 13 subaward recipients. Corrective Action: SEC will review and assess all federal grant award agreements, the reporting requirements, and guidelines to follow for each. SEC has hired additional staff and delegated to them the role of reporting requirements for SEC upon completion of the assessment. Those reporting requirements include the following: • Send monthly reminders to all project managers for all new / updated contracts or sub award agreements signed to be sent out 5 days prior to the end of each month. • Compile all data received from project managers and record in tracking spreadsheets for each specific grant by the 5th of the following month. ARDOR • Send cover sheet and all contracts or sub awards signed in the previous month to SEC's Chief Financial Officer (CFO) for FFATA reporting by the 7th of every month. • Train finance staff for FFATA reporting and compliance guidelines, completed by 1/31/24. • Engage in semiannual compliance reviews with an experienced federal audit consultant. In addition to the FFATA reporting, the executive assistant will also review with the CFO all reporting requirements for all grants and contracts whether they are monthly, quarterly, semiannually, or annually. Once this review and assessment is completed, the executive assistant will develop an internal reporting calendar and execute the following: • Regular reminders based on reporting requirements to all project managers and the finance staff for all related progress and financial reporting. • Follow up with project managers and finance staff 10 days prior to the deadline to ensure all reporting has been completed. Anticipated Completion Dates: • Grant award review 1/15/24 • Development of compliance corrective action 1/20/24 • Implementation of compliance reporting 1/20/24 • Finance staff training FFATA 1/31/24 • Additional BBB finance technician training 2/05/24 Responsible individual: Robert Venables, Executive Director. SEC and their contracted CFO have discussed the corrective action plan and are working cooperatively to ensure that all deadlines are met for compliance and training. Thank you, Robert Venables Executive Director

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Corrective Action Plan: College Unbound has increased its administrative capacity and has implemented internal controls to properly track, account for and report on grant expenditures. CU hired the Vice President for Student and Institutional Sustainability in 2023 and subsequently a Controller and Bursar were hired in October 2023 to support the growing needs of the college. The Chief Development Officer, Program Staff and the Financial Team including the VP, Bursar, Financial Aid, and Controller have developed routines and procedures to ensure we are using grant funds as intended and have proper documentation. We are in the process of developing procurement protocols to align with federal grant expectations. Timeline for Implementation of Corrective Action Plan: Currently updating procedures to ensure compliance for FY25. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO

2023-002 – Allowable Costs/Cost Principles Recommendation: We recommend that PPS enhance its procedures and internal controls to ensure that it retains documentation supporting time and effort on federal grants and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Special Education and related services, in collaboration with Portsmouth Schools Finance department will monitor that the certification of pay certifications are completed on a semi-annual basis. Finance will communicate via email, the list of personnel required to have the certification and also review once they are completed by the Office of Special Education. Finance will review all dates and signatures. Name(s) of the contact person(s) responsible for corrective action: Pamela Battle-Hardy, Director of Special Education and Related Services Planned completion date for corrective action plan: January 1, 2025

Finding: Reporting Corrective Actions Taken or Planned: The Authority is in the process of reporting all loan commitments related to the Capital Magnet Fund. Going forward, this step of the reporting process has been incorporated into the loan commitment closing process requiring one individual to input the information in the FSRS controls, then receive supervisor review and approval before submitting the information. Contact person(s) responsible for corrective action: Terry Barnard - Manager Community Development Lending. Anticipated completion date: 6/30/2024

2023-003 - Allowable Costs/Cost Principles – Internal Control and Compliance over Allowable Costs/Cost Principles (Significant Deficiency) Condition: During our audit, we noted that three (3) out of forty (40) samples summed up to $39,055.50 had no proper source documents to support the transactions charged to the grant brought by lost official receipts, hence, identified as not adequately documented. Alternatively, the City created a memo to document the loss of receipts signed by the department head. Management concurs. Corrective Actions: The City has an existing purchasing policy and procedures requiring documentation of all purchases made. Finance department has already sent a reminder to all department heads regarding the policy and procedure and why they must comply. Implemented Name of Responsible Person: Manuel Carrillo Jr., Director of Recreation & Community Services

CONDITION: During my review of The School District of the City of Jeannette’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, or 2) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors – Grade Point Resources ($74,503.17) and VLN Partners, LLP ($52,750.00). CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $$22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding.

MANAGEMENT’S PLANNED CORRECTIVE ACTION: For acquisitions of property or services in which the aggregate dollar amount is greater than the micro-purchase threshold but does not exceed the simplified acquisition threshold, the District will obtain and document price or rate quotations from at least three qualified sources. The District’s timeframe for implementation is during the start of the 2023-2024 fiscal year and continuing forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor the implementation of procurement procedures to ensure that they are followed appropriately.

Finding 2023-002-Subrecipient Monitoring Finding: The Foundation did not have a subrecipient monitoring policy under 2 CFR 300, .331 and 501(h), however it was noted that monitoring is occurring. Corrective Actions Taken or Planned: The Foundation will develop a formal subrecipient monitoring policy to conform to 2 CFR 200.300, .331 and 501(h). Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.

Department of Health and Human Services 2023-005 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Indirect cost expense was improperly calculated. Auditors’ Recommendation: We recommend the institution strengthen its internal controls to ensure that calculations are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: UMMC’s transition to Workday resulted in the need for multiple F&A bases to be created in Workday to accommodate our DHHS negotiated agreement. However, since our go-live we have only been using one modified total direct cost base to calculate F&A. UMMC is in the process of engaging a Workday Certified consulting firm to review the operational efficiency of Workday for Post-Award Accounting. The scope of this engagement will be to align our usage of Workday to industry best practices, including best practices for F&A calculation. During the scope of this project, we will review these established bases to ensure they meet the needs of our negotiated rate agreement provisions. In the meantime, we are reviewing the F&A calculations on existing projects when an invoice or financial report is prepared to ensure accuracy. F&A will be recalculated with each invoice and/or financial report and any necessary adjustments will be made before the invoice or financial report is submitted to the sponsor. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

Re: Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Mental Health America, Northern Kentucky and Southwest Ohio agrees with the audit finding. Corrective Action: Mental Health America, Northern Kentucky and Southwest Ohio will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Elizabeth Atwell, Executive Director eatwell@mhankyswoh.org (513)721-2910 Projected Completion Date: On or before June 30, 2024

COMMUNITY DEVELOPMENT BLOCK GRANT/ ASSISTANCE LISTING 14.228; HIGHWAY PLANNING AND CONSTRUCTION CLUSTER, ASSISTANCE LISTING 20.205 / WRITTEN POLICIES AND PROCEDURES/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D-POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. THE CITY OPERATES UNDER APPROVED WRITTEN POLICIES FOR PROCUREMENT AND CONFLICTS OF INTEREST, BUT THE APPROVED WRITTEN POLICIES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE, AND WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. / THE CITY IS IN AGREEMENT AND IS DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL THAT WILL ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT TO CONFORM TO THE UNIFORM GUIDANCE.

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

February 14, 2024 City of Bellevue, Kentucky Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 Audit Findings Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: The City of Bellevue, Kentucky agrees with the audit finding. Corrective Action: The City of Bellevue, Kentucky will prepare written procedures governing the expenditures of Federal Funds. : Name of Contact Person Lindy Jenkins City Clerk / Treasurer (859) 431-8888 Projected Completion Date: On or before June 30, 2024

Executive Director of Finance: Management agrees with this finding. The school district converted to a new financial ERP system as of July 1, 2023. The new ERP system flags any duplicate invoice numbers that maybe entered. The Accounts Payable (A/P) staff will verify if payment has already been made. On occasion, payment requests do not have an invoice number. To prevent duplicate payments, the Accounts Payable staff require original invoices and uses a system generated invoice number, or a will use a manual entry numbering convention to prevent duplicate invoice numbers. The invoice data is entered by an Accounts Payable specialist and reviewed by the Accounts Payable Manager. On occasion, A/P must request corrected invoices from vendors who try and reuse invoice numbers. The A/P Manager reviews invoice numbers during the check run for accuracy. Purchasing and A/P will also periodically review the vendor database for duplicate vendors. For construction projects that list a pay application number instead of an invoice number, A/P will implement a consistent invoice numbering convention to avoid duplicate payments. The A/P specialists will also review the PO payment history prior to processing. Responsible party(ies) for corrective action(s): Accounts Payable Manager Corrective action(s) timeline: December 1, 2023

Re: State Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Sanitation District No.1 agrees with the audit finding. Corrective Action: Sanitation District No.1 will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Debbie Vinson, Accounting Manager dvinsonsd1.orq (859) 578-7462 Projected Completion Date: On or before June 30, 2024

CORRECTIVE ACTION PLAN Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: 21.027 Federal Agency: Department of the Treasury ? Pass-through from the State of California Award No.: WWID 4SSO10370 & CA 1910156 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs Name responsible for correction action plan: Emily Armstrong, Revenue Services Manager The corrective action planned: Payments applied to the 93 water bills and 81 wastewater bills will be reversed on the customer?s accounts. A notice will be issued to customers via mail and email (where possible) of the discrepancy. The funds will be returned to the State pursuant to their outlined procedures. Moving forward, the City will ensure that there is a multi-layered approval process to review the eligibility period of any State funding to identify the correct eligible applicants prior to disbursement. For future funding related to water and/or waster bills, the list of eligible applicants will be compiled by an analyst within the department and will be reviewed by the Revenue Services Manager and Assistant Finance Director prior to disbursement. Anticipated completion date: March 24, 2023

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management has updated Finance policies to capture the documentation and maintenance of such documentation of Supervisory review and approval.

Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board review its policies and procedures to verify that controls are inplace to ensure expenditures are not reimbursed under more than one Federal Program.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding: ESSER funds will no longer be used for Food and NutritionServices.Name(s) of the contact person(s) responsible for corrective action: BCPS grant managers,and Fiscal Services staff.Planned completion date for corrective action plan: For immediate implementation andongoing

2022-003 Formal Policies for Federal Awards Auditor Recommendation: We recommend management attend federal award trainings to ensure the documented policies and procedures can be performed as necessary. This will ensure the Center is in compliance with compliance requirements surrounding Federal awards. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Management with the Center?s Audit Committee will review and document policies and procedures for managing federal awards to supplement existing policies and procedures associated with awards from non-federal funders. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: August 31, 2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate. Anticipated Completion Date: June 30, 2022 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Finding 2022-003: Allowability of Costs (Research & Development Cluster) Name of Contact Person: David Thomas, Group Vice President & Controller Corrective Action Plan: To address the current year finding, Academic Project Portfolio Management (PPM) Labor team has implemented internal control improvements to ensure all requirements that limit the salary cap allowability of costs are completed and documented appropriately including communication and education of salary cap requirements with the business administrator, plus additional review from the Academic PPM Labor team. Proposed Completion Date: Management will complete the corrective action plan by December 2023.

Responsible Contact Person(s): Angela Wright, Director of Finance Corrective Action Planned: The Director of Finance has provided additional training to staff and is performing a detailed review of all reports to ensure accuracy. Estimated Completion Date: 2/15/2023