Corrective Action Plans

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods. 2. Approval Process: Present the drafted policy to leadership or the governing body for review and approval. 3. Implementation: Roll out the approved procurement policy to all relevant departments and stakeholders. 4. Training: Conduct training sessions to ensure staff understand and comply with the new procurement procedures. 5. Monitoring: Establish a system to regularly review procurement activities for compliance with the policy and federal regulations. 6. Implement a system of internal controls to ensure payroll charges are supported by accurate records reflecting actual work performed. This system should include regular reconciliation of estimated payroll allocations with actual time worked and documented certifications by employees or supervisors. Anticipate Completion Date – May 31, 2025 Responsible Contact Person – Monique Langston, Grant Director

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 vendor –– Beaver Valley Intermediate Unit ($332,200). 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 2024-2025 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: Voyager Sopris Learning ($49,117) and Questeq ($70,549). 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.

Finding 2024-002 – The Organization’s current documented procurement policy does not contain all the required elements identified within the Uniform Guidance. 2024-002 Recommendation: The Organization should adopt a formal procurement policy that complies with 2 CFR 200, Sections 200.318 through 200.327. Action Taken: Management agrees with the finding and will review the requirements under the Uniform Guidance relating to procurement and establish a formal policy and related procedures to comply with those requirements. Expected Date of Completion: June 30, 2025

In the future the Treasurer will ensure proper procurement methods are utilized.

The district will obtain more information from the Ohio Purchasing Council going forward on future projects.

Finding 2024-010 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295-01-01 Year: 12/01/2022 – 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

Finding 2024-002 Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

Environmental Protection Agency, passed through State of North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, Debarment Material Weakness Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Jordyne Lee, General Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements. Anticipated Completion Date: December 31, 2025.

RIDE has a template it provides to LEAs in order to request proposals from Food Service Management Companies. The documentation required for the RFP process is robust but doesn’t currently require a written code of standards conduct. RIDE will add an appendix to the RFP template in order to require LEAs to submit a written code of conduct as a part of the RFP process for sourcing Food Service Management Companies. Anticipated Completion Date: Prior to July 1st, 2025 Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov

Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Recommendation: Management should draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the recommendation noted above by May 31, 2025.

The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the procurements. The District will assign someone in the District office to review procurement requirements and ensure contracts meet the District’s policies. Shannon Grindell, Susan Mayer Ongoing

Views of Responsible Officials and Planned Corrective Action The County has a written policy regarding Federal Grants that was passed by the Grant County Commissioners in January 2025. Finding resolution timeline: Resolved. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager

Federal Agency Name: U.S. Department of Treasury Assistance Listing Number(s): 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Finding Summary: Non-Federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the Non-Federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. It was noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Responsible Individuals: Kyle Wilmot Canyon County Controller Corrective Action Plan: Members of the audit office will review each vendor in the SAM.gov database to ensure that they are not suspended, debarred or otherwise excluded. The search of these entity(s) will then be saved to the shared drive for the upcoming ACFR season and the supervisor will be notified of the search to ensure that the files have been properly saved. Anticipated Completion Date: Canyon County will complete the corrective actions for the September 30, 2025, reporting period.

Audit Finding Summary: 2024-002 The Organization did not establish or follow sufficient internal controls to ensure compliance with federal procurement requirements, including maintaining the required documentation for procurement activities. Corrective Action Plan: Contact Person Responsible for Corrective Action: Wendi Gephart, Federal Contracts and Grants Compliance Manager wendi@movementstrategy.org | (510) 956-3849 Planned Action: MSC recognizes the need for improved procurement documentation and internal controls. To strengthen compliance with 2 CFR 200.318-326, MSC will take the following actions. Revised Procurement Policies: MSC is updating its procurement policies and procedures to reinforce adherence to federal regulations, ensuring full and open competition in all procurement transactions. Enhanced Documentation and Record-Keeping: A comprehensive process will be established to maintain detailed procurement records, including justification for vendor selection, contract pricing, and competitive bidding results. This will ensure transparency and compliance with federal requirements. Staff Training in Federal Procurement Standards: MSC will provide training to staff on procurement regulations, including conflict-of-interest policies, documentation requirements, and competitive bidding procedures. Periodic Compliance Review: Internal review will be conducted periodically to verify compliance with procurement policies and federal regulations. MSC remains committed to continuous improvement in financial and compliance practices to uphold the integrity of its federally funded programs. Expected Completion Date: June 30, 2025

We will comply with the procurement policy. I have already submitted the information to ODEW for FY25.

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 2024-003 Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2023-003) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Planned Corrective Action: While procurement requirements are followed, management concurs that the documentation of procurement activities does not always occur. The Payables Manager will gather all procurement documentation with the purchase order request, and work with all Operations Directors to ensure proper procurement activities are performed. Michelle Krauter, VP, Chief Financial Officer, will approve all purchase order requests. This documentation will be retained with the approved purchase order and invoices. Michelle will ensure all compliance requirements are followed and appropriately documented.

Procurement and Suspension and Debarment – Clean Water State Revolving Fund – Assistance Listing No. 66.458 Recommendation: We recommend that the organization develop and implement a formal, documented policy for procurement and suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on implementing a formal, documented policy for procurement and suspension and debarment. Name of the contact person responsible for corrective action: Steve Schaefer, Trustee Planned completion date for corrective action plan: Ongoing consideration

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2024-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District has updated its policies and procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The updated procedures include steps so that district personnel are following the requirements of the Uniform Guidance related to methods of procurement and suspension and debarment requirements including maintaining appropriate documentation. Official Responsible – The District’s Director of Finance and Operations, Mark Kumlien Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – The District’s Director of Finance and Operations, Mark Kumlien, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, and suspension and debarment requirements.

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Corrective Action Plan: The Authority acknowledges the finding and is currently working to correct this. Responsible Official: Contact person is Todd Shurn, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2025

CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding Reference Number Corrective Action Responsible Person Anticipated Completion Date Finding 2024-001: Internal Control Over Financial Reporting Because of its size, the City does not feel it is cost effective to hire an additional employee(s) with the experience, technical training and time to prepare its financial statements. Draft copies of reports are reviewed and approved prior to their issuance by management. As such, management will continue to rely on the auditors to assist in preparing the City's financial statements and schedule of expenditures of federal awards and assist with certain year-end adjustments. Blyann Johnson Ongoing Finding 2024-002: Internal Control Environment The City is aware of the lack of segregation of duties caused by the limited size of its staff. Segregation is enhanced whenever possible and the council assumes an active role through monthly review of receipt and disbursement transactions and monthly financial statements. Blyann Johnson Ongoing Finding 2024-003: Significant Deficiency - Internal Control Over Procurement, Suspension and Debarment City personnel will make every effort to familiarize themselves with the rules of the Federal Awards programs. Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Blyann Johnson 12/31/25

Significant Deficiency over Procurement Contact Person Responsible for the Corrective Action Plan: William Roberson, Financial Services Director Corrective Action Plan: The County identified a problem during the fiscal year, corrected the issue during the fiscal year, and shared the information with the audit team. Procurement for the new radio read water meters began with informal solicitation of pricing during the prior administration which ended in February 2023. The lack of formal procurement was identified as an issue by the interim county manager and recommended that the County reject the three informal bids. Subsequently, the County initiated a formal procurement process and is documented in meeting minutes, and a copy of County Administration’s memorandum to the Board of Commissioners was shared with the audit staff early in the audit process. The project was approved and contract awarded on July 5, 2024. Anticipated Completion Date: Completed

Recommendation: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the federal law and standards identified in 2 CFR 200.318 through 2 CFR 200.327. A procurement policy that aligns with these federal requirements is currently being developed. The policy is expected to be adopted and in place in the coming months. Name(s) of the contact person(s) responsible for corrective action: Angela Woods Planned completion date for corrective action plan: June 2, 2025

Management Response: The Mifflinburg Area School District agrees with the finding. The SFA has updated Policy #626 Procurement - Federal Programs. The SFA has removed the RFP reference from the informal procurement method. The SFA reviewed the bidding requirements and will adhere to the policy. This policy was approved by the School Board in May 2024. The SFA has updated future produce solicitations to include the following: Pricing will be a cost-plus fixed fee structure. All prices bid for all products will be net, Free on Board (F.O.B.). SFA will consider individual product price changes both as part of a renewal to the awarded contract and during the contract year. Product price changes may not exceed the U.S. Department of Labor-Bureau of Labor statistics Northeast region not seasonally adjusted consumer price index percentage change annual average for the previous 12 months. Vendors must submit both the supplier charge and the fixed fee, which much be listed separately. Additionally, the SFA implemented a formal requisition process in the Food Service department, in which pricing would be entered into the requisition and verified against the bid or other respective documents, then submitted for approval. The SFA employees responsible were trained in this procedure. Individual Responsible: Superintendent, Business Manager, Food Service Director Anticipated Completion Date: May 31, 2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Name of contact person: Peri Whiteclay Corrective Action: Checking the SAM system was added to the county’s grant management procedures after the audit of fiscal year 2023. Proposed Completion Date: Completed.