Corrective Action Plans

CORRECTIVE ACTION PLAN (Concerning Finding 2023-007) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-007 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and drafted, has had approved, and has implemented the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024

CORRECTIVE ACTION PLAN (Concerning Finding 2023-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-004 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and is using the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024.

The following is Management’s Response to the Findings Required to be Reported by the Uniform Guidance. This document was prepared by management of the Catholic Charities of the Archdiocese of Oklahoma City (“CCAOKC”). 2023-002 Assistance Listing Number 93.576, Refugee and Entrant Assistance Discretionary Grants, U.S. Department of Health and Human Services, FAIN 90RP0121, Award Year 2023, Passed Through by the United States Conference of Catholic Bishops Criteria or Specific Requirement – Procurement, Suspension, and Debarment – 2 CFR § 200.317–.327; 2 CFR § 200.214 Finding Summary CCAOKC’s procurement documentation procedures were not adequate to meet the requirements of 2 CFR § 200.317–.327; 2 CFR § 200.214 - Procurement, Suspension, and Debarment. Explanation of Agreement/Disagreement: Management concurs with the findings and has updated CCAOKC’s procurement policy. Officials Responsible for Ensuring Corrective Action: David Ashton, Sr Director of Administration; E-mail – dashton@ccaokc.org Alan Lipps, Chief Financial Officer; E-mail – alipps@ccaokc.org Planned Completion for Corrective Action: Corrective action completed in FY 2026 Action in response to finding: Purchasing staff are trained in federal procurement requirements and were provided with a copy of the new policy.

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2023 AUDITOR FINDING: 2023-006 In accordance with 2 CFR Part 200.318 the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The Organization's purchasing policy did not contain elements of federal procurement requirements specified by Uniform Guidance. CLIENT PLANNED ACTION: The Organization will revise the Procurement Policy such that it is consistent with the appropriate regulations and standards and requires documentation of the vendor procurement policy. CLIENT RESPONSIBLE PARTY: Danielle Cordova, Controller COMPLETION DATE: July 1st, 2025

FINDING 2023-004 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Completion Date: June 2026

Corrective Action Plan Action Item Responsible Party Monitoring Require that procurement transactions be properly identified and tracked by federal program to ensure completeness and traceability. CFO / Procurement Staff Monthly review Maintain complete procurement documentation, including records of competition, procurement method, and verification of suspension and debarment in accordance with federal requirements. CFO / Procurement Department Periodic internal review Reconcile procurement-related expenditures to the SEFA and underlying accounting records to ensure a reliable population for compliance testing. CFO Documented reconciliation In FY 2026, management developed and implemented a formal Records Retention Policy to ensure that accounting records, supporting documentation, and organizational records are properly maintained and retained in accordance with applicable regulatory and audit requirements CFO Management oversight Implement supervisory review of procurement activity to ensure compliance with federal procurement requirements. CFO / Board Finance Committee Quarterly review ________________________________________ Management Response Management notes that no additional federal grants, other than the HRSA Section 330 program grant (Assistance Listing 93.224), were received in FY2025 or FY2026. Prior management did not provide a reconciled SEFA schedule for earlier reporting periods, which contributed to the documentation limitations identified during the audit. Beginning in FY2026, management has developed a detailed SEFA tracking schedule for the HRSA Section 330 grant that identifies the date federal funds were drawn down, the amount received, the related expenditures, and the corresponding disbursement dates. This schedule is maintained to improve reconciliation between drawdowns, expenditures, and the general ledger and to ensure documentation is readily available for audit and compliance purposes. In FY2026, management implemented an updated and comprehensive set of policies and procedures designed to strengthen internal controls and promote consistent, standardized accounting and administrative practices. These updates establish clearer documentation requirements, defined responsibilities, and improved oversight to ensure compliance with applicable regulations and the safeguarding of organizational records and financial information. ________________________________________ Responsible Official: Chief Financial Officer Expected Completion Date: FY 2026

Conditions 1-2: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 3: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 4: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

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.

VIDE acknowledges the audit finding regarding the Consolidated Grant procurement documentation and concurs with the recommendation. VIDE recognizes that the unavailability of approved Short Form Contracts during the audit indicates a gap in record retention and file maintenance. To address this, the Business Office will not process any payment voucher for service-related procurements unless the approved Short Form Contract is attached to the ERP transaction as a mandatory supporting document. To ensure records are maintained and readily available for future reviews, the Procurement Division will digitize all executed Short Form Contracts and upload them to the department’s centralized SharePoint repository immediately upon execution. To reinforce these protocols, mandatory refresher training will be conducted for Procurement and Program staff on the new digital archiving requirement and the federal documentation standards for service-related procurements. Finally, the Office of Fiscal & Administrative Services will conduct monthly spot checks of the SharePoint repository to verify that all active service contracts are properly archived and accessible.

The Government concurs with the auditor’s findings and recommendations. The Government updated its procurement laws and issued revised manuals, along with position-specific Standard Operating Procedures. Processes to enforce internal controls and ensure adherence to procurement laws have been established and are regularly reinforced.

The Department of Health concurs with the Auditor’s findings and recommendations. To ensure that the WIC program is included in all processes and receive all documents and correspondence relating to WIC Special Funding as a secondary oversight of the transactions.

The Department of Health (DOH) concurs with the auditor’s findings and recommendations. The DOH will work closely with DPP to improve their internal controls to ensure adherence to federal regulations relating to the procurement of goods and services. DOH will encourage DPP to review current records retention policies. To address this, there will be timely coordination and communication with DPP and the Department of Health for the handling and managing of procurement tasks.

Personnel Responsible for Corrective Action: Eljana Kaziaj, Controller Anticipated Completion Date: ASAP. Goal Date is August 31, 2025 Corrective Action Plan: Management accepts the recommendation. It will modify and strengthen our policy and procedure regarding the procurement process to reflect the alignment with federal regulations. Will also maintain a suspension and debarment on vendors. The list will be reviewed monthly.

Action Item Title 2023-005 – Federal Award Findings Status (Open: In-process) Condition General Procurement Standards - Written Policies Suspension and Debarment - Covered Transaction The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements. From a sample of eighteen disbursements, we selected eight disbursements to ascertain compliance with 2 CFR section 180.220, specifically regarding the inclusion of procurement contracts as covered transactions. We examined the procurement documents provided by the Corporation. From that sample, we identified that the Corporation did not perform the required verification process for covered transactions during the year ended June 30, 2023. Identified root cause The Corporation lacks internal controls and policies to ensure compliance with federal procurement requirements. In addition, the Corporation relies on the procedures performed by the Administration of General Services to comply with procurement requirements. As a result, the Corporation did not maintain its own documentation. Grantee resolution plan Procurement Policies and Covered Transactions The Corporation is currently in the process of reviewing its Procurement Procedure to align it with ASG guidelines and incorporate federal regulations. Completion date By December 31, 2025. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Vendor status for 2023 recipients was retroactively evaluated by CUAHSI staff and certified by management during calendar year 2024. Records were organized and filed in a secure, centralized document management system. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding closed, as current practices comply with established policies and procedures. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31, 2025

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: RiverView amended the policy on June 17, 2025, CLP amended the policy on July 3, 2025. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

Finding Number 2023-109 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The finding states two ongoing concerns: “1) there are no policies and procedures in place for the people on [the pilot program] Statewide Contracts [as is required by 2 CFR § 200.317], and 2) these vendors are not being vetted to ensure state agencies are getting contracts that are reasonable per 2 CFR 200.404.” On the first issue, Section 200.317 of Title 2 of the Code of Federal Regulations requires states to “follow the same policies and procedures it uses for procurements with non– Federal funds” when “conducting procurement transactions under a Federal award.” 2 CFR § 200.317. Our publicly available CPO training explains the process for purchasing off Statewide Contracts (See Attachment 1 and 2). Also, we provided agencies with procedures related to the pilot program to give guidance on ordering off those specific Statewide Contracts (See Attachment 3). Additionally, OMES reiterates that Recipients of federal funds are ultimately charged with ensuring and documenting compliance with specific requirements under the federal award. However, in an attempt to assist agencies in understanding requirements of spending federal dollars, OMES issued a Procurement Information Memorandum and a new contract attachment to be utilized by agencies. (See Attachments 4 and 5). Therefore, OMES disagrees that we do not have the required policies and procedures in place to comply with Section 200.317. On the second issue, Section 200.404 of Title 2 of the Code of Federal Regulations explains, “A cost is reasonable if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost.” All our Statewide Contracts are evaluated on specific criteria, including pricing. If a bidder’s pricing appears to be unreasonable, they do not receive an award. Additionally, in Attachment 3 it is demonstrated that when an agency ordered from the pilot program Statewide Contracts, the Information Services Division (“ISD”) of OMES works with the agency and the supplier to develop a Scope of Work (“SOW”). The SOW is comprised of detailed deliverables and pricing for the relevant goods and/or services. ISD stakeholders are subject matter experts in the relevant work and ensure that all pricing on SOWs is fair, competitive and reasonable. Therefore, OMES also disagrees with the assertion that the vendors on contract are not vetted to ensure that state agencies are getting reasonable costs on their contract. OMES further reiterates that we believe the relevant solicitations were conducted pursuant to the requirements of the Statewide Contract pilot programs and meet competitive bidding requirements. The Statewide Contract pilot programs utilized the same initial procedures as all other Statewide Contracts prescribed in statute. Vendors are required to agree to standard state terms and submit competitive pricing for the goods and/or services within scope of the solicitation. OMES identifies evaluators for every solicitation to conduct an evaluation process relevant to the particular scope of services and to negotiate price when choosing responsive and responsible suppliers. In conclusion, OMES respectfully disagrees with the concerns of the State Auditor’s Office and invites any member of the State Auditor’s team to meet with OMES personnel to further clarify our processes and standards for ensuring fair and competitive procurement practices. Anticipated Completion Date Sine Die Responsible Contact Person

2023-003 Documented Procurement Policy Contact Person - Erin Metcalf, Finance Director Description of Corrective Action - The organization has implemented a new procurement policy that is compliant with state and federal regulations. Completion Date - June 30, 2025 Root Cause - Historically, the organization had very minimal procurement activity; that combined with rapid growth of the organization resulted in outdated policies.

Finding 2023-007: Significant Deficiency, Procurement and Noncompliance Finding – Procurement – Internal Control over Procurement Finding: SPED/Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases-Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. The DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, the City did not follow their own procurement policy requiring two quotes for a micro-purchase expenditure, three quotes for a small purchase expenditure and advertising for bids publicly for the large >$5,000 purchase expenditures. They only obtained one quote for each expenditure for micro and small purchases, and they did not use a public bid process for expenditures over $5,000. Corrective Action Taken or Planned: Danbury Public Schools (DPS) will begin reviewing the procurement policies that are in place in order to ensure they are in accordance with all compliance requirements set forth by any grants that DPS participates in. A memorandum will be issued summarizing procurement policy features. Lastly, training will be conducted with both the department and the finance team to review the policies and ensure understanding.

Program 66.958 Water Infrastructure Finance and Innovation Award No: WIFIA-N18147WI Award Year: 2023 Finding 2023-001: Procurement policy and related contract Repeat finding of 2022-001Waukesha Water utility management has worked closely with WIFIA to craft contracts that include all necessary language prior to releasing RFPs for construction contracts. WIFIA was presented all service contracts to review prior to reimbursements received in fiscal year 2023. The finance department is working to update the procurement policy to ensure necessary federal language is included. The finance department will also work with service contractors to execute contract addendums

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension and Debarment Summary of Finding: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. INDIANA STATE BOARD OF ACCOUNTS 41 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation could not provide supporting documentation that an adequate number of price or rate quotations was obtained to ensure full and open competition for two vendors procured under the small purchase threshold. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The procurement method used to purchase equipment costing over $10,000 will be documented and archived with the purchase order. Anticipated Completion Date: July 31, 2024

COVID-19 Coronavirus State and Local Fiscal Recovery Funds —Assistance Listing No. 21.027 Recommendation: We recommend the District design controls to ensure an adequate review process is in place to review potential contractors to determine compliance with the Uniform Guidance procurement rules and procedures. Procedures for approval of the vendor contracts, and verification documents to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration, should be reviewed and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to confirm to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager, or Delia Stoor, Accounting Manager Planned completion date for corrective action plan: September 30, 2024

Finding: 2023-004 Significant Deficiency in Internal Control over Compliance U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Finding Summary: We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing: 1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Responsible Individuals: Dana Aschenbrenner, Finance Director Corrective Action Plan: The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen. Anticipated Completion Date: Ongoing