Corrective Action Plans

The City of Dos Palos was on a state of emergency Resolution, and when these funds came available, understood that we could go forward with the rehabilitation of our 750,000 gallon tank, for storage for the City. In the future, if an emergency situation should arise, the City will review all regulations and documents for procurement of the funds. The City's procurement policy is outdated and we will be implementing a new written procurement policy.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023

Finding 2022-001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing #14.134 Procurement, Suspension, and Debarment Finding Summary: The Project does not have a written procurement policy which conforms to Uniform Guidance as outlined in 2CFR 200.317 through 200.327. During the year, management entered into transactions over the micropurchase threshold with eight vendors. Documentation was unable to be provided to support procurement compliance for seven vendors. In addition, there was one vendor with expenditures in excess of $25,000 and the Project did not verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Responsible Individuals: Sue Lund, Administrator Corrective Action Plan: The Project is drafting a written procurement policy which conforms to Uniform Guidance as outlined above. In addition, for expenditures in excess of $25,000, the Project will verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Anticipated Completion Date: July 2023

SEE ATTACHED

The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review_vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and_Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached._At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document_from SAM.GOV verifying eligibility of vendor will be attached to the vendor file.

Views of Responsible Officials: The funds were needed to be made immediately available to those who were in need because of the Coronavirus pandemic, which had made a serious impact on the homeless and those who were about to become homeless. Due to the urgency of the situation, it was determined to be in the best interest of those in need to follow a faster process to disburse funds than to advertise requests for proposals, evaluate the proposals to make selections, and award contracts. Written procedures will be established for use of the alternative procedures.

FINDING 2022-005 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

Action Taken: The Home will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.

Management Comments and Corrective Action: During the course of the single audit for the year ending August 31, 2022, it was noted that SWK "legacy" contracts did not follow the established procurement policy and procedures which requires SWK to obtain quotes from at least three sources and/or did not document the quotations in the procurement file for one expenditure between $25,000 to $100,000. This instance of noncompliance noted was for a consumer goods (i.e., clothing, and personal healthcare). Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized an existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization, hired new procurement leadership and invested Full Time Employees (FTEs) to develop a robust procurement department. As a result of this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provided tools for the selection of the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2023. Person Responsible for Corrective Action: Fred Muniz, CFO 2023

FEDERAL AWARDS – CORRECTIVE ACTION PLAN REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT – MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity 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. Condition/Context: Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division must maintain records sufficient to detail the history of procurement. These records should 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. Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed and implemented a formal written procurement policy aligned with applicable federal requirements and organizational purchasing practices. The policy includes required procurement methods, thresholds, documentation standards, conflict-of interest provisions, and approval authority levels. In addition, the Organization has implemented internal monitoring controls to track cumulative vendor spending throughout the fiscal year and to ensure that procurement procedures are properly initiated when vendor costs approach or exceed established procurement thresholds. Staff responsible for purchasing and vendor management have been trained on the updated requirements and documentation expectations. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

The City acknowledges and agrees with the finding regarding procurement deficiencies during the administration of ARPA funds. Since the time covered by the audit, the City has taken significant steps to strengthen internal controls over procurement. A full-time Purchasing Manager has been appointed to oversee and enforce compliance with both City and federal procurement standards. In addition, the City is currently updating its procurement policy to ensure clearer thresholds, detailed procedures for informal bidding, and approval workflows aligned with 2 CFR Part 200. All procurement staff are being trained on the revised procedures and control mechanisms. These updates are being documented, and we have introduced internal review checkpoints prior to purchase order execution. We are also developing a procurement checklist and digital authorization process to ensure documentation is complete before funds are obligated. This will prevent similar deficiencies from recurring.

Finding Reference Number: MW2021-007 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: Vendor status for 2021 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. Vendor onboarding now includes a required disbarment check conducted by the Director of Finance. In 2024, new procurement requirements were added to clarify thresholds and competitive procurement processes, and an approval certification step was implemented for all vendor payments. This monthly certification, performed by the Director of Finance or Executive Director, ensures that payment recipients are not suspended or disbarred. 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 2021-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education) Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO

Finding 2021-005: Procurement Federal Programs: Research and Development Cluster: All Grants Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quots were not obtainable or the conclusion for the selection was not documented. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the policies. Management will be responsible for proper documentation and confiramtion that all policies and procedures are followed. Management will confirm that all agreements, mou's and contracts are properly, reviewed, signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan, CFO

The administration will review the procurement policy in the next management meeting. Division Directors will review the procurement policy with all Program Directors and Managers. Also, see actions for 2021-003

Finding 2021‐010 Sole Source Vendors – Procurement and Suspension and Debarment – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan The City will follow the Uniform Guidance thresholds that are established for federal programs, as well as follow the City Council’s policy. Expected Completion Date Fiscal Year 2025.

The Treasurer, Town Manager and Select Board will take the following actions to address finding 2021-007 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 has drafted a new Procurement Policy that addresses this deficiency. The Select Board will review this draft at their meeting in January 2024, edits will be made and then it will be sent to legal for final review before adoption.

The Treasurer, Town Manager and Select Board will take the following actions to address finding 2021-004 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 a new Procurement Policy that addresses this deficiency. The Select Board will review this draft at their meeting in January 2024, edits will be made and then it will be sent to legal for final review before adoption.

Management of the Organization has stated the process of creating new and updating policies, procedures related to financial reporting, activities, including written procurement standards and written conflicts of interest.

Management Response to Audit Comment # 2021-005 INTERNAL CONTROLS OVER DISBURSEMENTS OF FEDERAL FUNDS MUST BE IMPROVED HEAD START AND EARLY HEAD START PROGRAMS Federal Assistance listing # 93.600 Responsible Person: G. Keith Williams/ CCCSA Management Anticipated Completion Date: December 31, 2023 Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and takes exception to several of the items listed. For example, some of the transactions listed that were missing check requests (both Head Start/Early Head Start and Indirect Cost Pool) were for monthly expenditures like utility bills, insurance, rent and other contractual obligations. Management has not in the past issued a check request each month for these transactions as they are a part of the ongoing operation of the programs listed. Transactions listed with only one signature occurred as an oversight as the banking authority only requires one signature while our policy may indicate two signatures. Management feels the purchase of the truck was procured in agreement with approvals from the funding agency and board as required. Proper documentation was provided and is currently available for further review. Management continues to follow the proper guidelines regarding procurement and purchases related to the policies and procedures of the agency as well as micro purchase guidelines set forth by the Federal awarding agency. The Board of Directors also approved a revision to the policies and procedures requiring two “live” signatures on all checks issued by the agency. There is also an ongoing review of the current policies and procedures and recommendations for changes and updates are forthcoming. Management reserves the right for further review of these findings with the audit firm for additional documentation and resolution.

That the Borough follow the DGLS guidelines for purchases over $44,000, which includes publicly advertising for sealed bids on contracts over $44,000. The Police Chief with the Purchasing agent will bid next time this situation presents itself.

The County will make sure that all federal documentation is maintained by each district for inspection and will ensure it is accurately reported on the SEFA.

I am aware of the audit findings involving FEMA Disaster 4315. I apologize for the delayed response letter. On behalf of Dewey County District 2, we want to assure you we are here to help and assist in anything you or your office may need from myself, or from any District 2 employee.

Finding Reference Number: MW2020-007 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers the finding to be closed as current practices are compliant and adhere to appropriate policies and procedures. When vendors are onboarded by CUAHSI, a check on disbarment is required and the CUAHSI Director of Finance performs this verification. New procurement requirements were added to CUAHSI policies in 2024 to clarify thresholds and processes for competitive procurement. Also in 2024, an approval certification step was added for all outgoing vendor payments, requiring a monthly certification by the Director of Finance or Executive Director to ensure those receiving payments from CUAHSI are not suspended or disbarred. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete