Corrective Action Plans

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non-compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

The district will create an SOP for procurement activities moving forward as well as making sure to train staff responsible for procurement to ensure compliance with Federal compliance.

The procurement policy will be formally reviewed and revised to ensure full alignment with 2 CFR Part 200.317–200.327. The updated policy will clearly outline all allowable procurement methods, including micro-purchases, small purchases, sealed bids (formal advertising), competitive proposals, and noncompetitive procurements. Management expects to have this implemented by April 1, 2026. The process is being monitored by Anthonia Ibe, Chief Financial Officer.

Finding 2024-003 Material Weakness in Internal Control over Compliance Name of responsible official: Evan Howard – Business Manager Corrective action: The municipality is in the process of reviewing roles, responsibilities, and job descriptions to ensure appropriate segregation of duties and proper internal controls, in accordance with the Corrective Action Plan. The plan has not yet been formally adopted. Anticipated completion date: June 30,2026

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

View of Responsible Official: A written SOP was developed for determining allowable costs and procurement requirements in accordance with the applicable CFR to guide key finance staff with responsibility for federally eligible expenditures. Anticipated Completion Date: April 30, 2026 Responsible Contact Person: Rhonda Williams, Financial Director

2024-005 – Procurement and Suspension, and Debarment – Internal Control over Procurement and Verification Against the System for Award Management (“SAM”) City’s Corrective Action Plan: The City acknowledges the finding and is in the process of implementing a formal procurement policy. This is currently under development and is expected to be approved by FY-26. To address these issues, the City will implement standardized procurement procedures requiring the use of purchase orders and direct invoicing, documented approvals, and verification of vendors’ eligibility for all projects. Procurement policies will include suspension and debarment checking using SAM.gov, and all supporting documentation will be retained in procurement files. Staff involved in procurement and grant management will receive training to ensure consistent compliance with the updated procedures and federal regulations. Responsible Person: Procurement Manager, Grants Manager, and CFO Expected Implementation Date: FY- 2026.

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained.

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager

Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for the projects selected. In conjunction with our fiscal year 2024 audit, please see the City’s corrective action plan below: To address the audit finding, management concurs with the finding that procurement documentation for CSLFRF‑funded projects was insufficient to demonstrate compliance with federal procurement standards, including the requirement for public notice under 2 CFR § 200.320(b). The absence of complete records limited the City’s ability to show that full and open competition was provided. The City will revise and strengthen its procurement policies to require formal solicitation and complete documentation for all applicable projects. A centralized system for retaining procurement records will be implemented to ensure that evidence of public notice, solicitation efforts, bid evaluations, and contract award decisions is consistently maintained. Staff involved in procurement will receive training on federal requirements, and a pre‑award compliance checklist will be introduced to verify that all required documentation is in place before contracts are executed. Management will work with all departments involved in procurement to reinforce expectations, implement improved procedures, and ensure that required documentation is consistently retained.

Every Woman's Place has fully implemented corrective action to address the induirect cost calculation and reporting issues identified in this exception. The Agency has formally adopted a signle direct allocation methodlogy, consistent with it FY2021 cost allocation plan, and has discontinued the use of de minimis or alternative indirect cost methodlogies. The cost allocation policy has been updated to clearly define the approved allocation medthod, allocation bases (included square footage, FTE, and usage where applicable), and the treatment of administrative and shred costs. This methodology is applied conssitently across allo programs and funding sources to ensure equitable distribution and compliance with 2 CFR 200 requirements. In addition, the Agency now requires annual board-approved certification of the cost allocation methodlogy. Allocation calculation are documented using standardized worksheets and reviewed as part of the monthly and quarterly financial review process to ensure accuracy and consistency prior to financial reporting and FSR submission. The procedures are documented in the Agency's Fiscal and Cost Allocation procedures manual and are fully operational

Corrective Action Plan Finding 2024-002 Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “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” 2 CFR section 200.318(i). Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Tim Stay, CEO Timeline: All future contract solicitations will follow the required procurement standards.

2024-003 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.

The procurement policy as well as all policies are reviewed every three years to comply with Joint Commission Standards. Saint Anthony will review its existing procurement policy to ensure that all elements required by the Uniform Guidance are incorporated. The review was completed on March 28, 2025.

Audit Finding: 2024-002 – Procurement Documentation Planned Corrective Action(s): SIG-NAL will strengthen its procurement controls by fully implementing the updated Procurement Policy and Standard Operating Procedure adopted in 2025. Standardized procurement documentation templates have been developed and are now required for all purchasing actions, including documentation of procurement method, contractor selection, and cost/price analysis. Compliance is monitored by the Director of Operations and reviewed periodically by the external accounting firm. The organization will require that all procurement records are completed and retained in accordance with 2 CFR §§ 200.318–320. Anticipated Completion Date ● Ongoing - Full implementation expected by March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

View of Responsible Officials: ICMEC is currently updating our written policies and procedures to ensure that the hiring and procurement process for contractors is properly conducted, reviewed, approved, and documented. In addition, ICMEC now requires a Procurement Memo to be prepared for each new contractor hired, outlining the procurement method, the hiring team, the selection process, the due diligence steps taken, and the contract details. These memos are prepared by the hiring supervisor or responsible Human Resources manager, reviewed by the organization’s General Counsel, and approved by the CEO.

Department of the Treasury Federal Financial Assistance Listing/ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: The Organization does not have a procurement policy that conforms to applicable standards under Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth in the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement policies required. Responsible Individuals: Steve Kuehneman, Executive Director, Bob Pawlikowski, Director of Finance and the Board of Directors of CARE Communities. Corrective Action Plan: Management agrees with the finding. Management and the Board of Directors have reviewed Eide Bailly’s procurement recommendations and will adopt a Board-approved Procurement Policy that complies with Uniform Guidance. The Organization will apply these procurement requirements to all applicable contracts and will review contracts to ensure inclusion of all provisions required under Uniform Guidance. Anticipated Completion Date: 2026

Finding Number: 2024-004 Finding Title: Procurement and Suspension and Debarment Program: 20.205 Highway Planning and Construction Name of Contact Person Responsible for Corrective Action: Jennifer Luhmann & April Wellman Corrective Action Planned: Faribault County Public Works will ensure all fiscally sponsored project files contain required documentation as stated in U.S. Code of Federal Regulations 200.318(i) and 180.300. Anticipated Completion Date: December 31, 2025

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

Finding 2024-001: Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Condition: During our testing of procurement for ALN 21.027, we noted that the City procured certain goods/services through the Commonwealth of Pennsylvania’s COSTARS cooperative purchasing program. For items selected for testing, totaling $184,512, the City did not conduct its own competitive procurement process. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. The City does not have implemented monitoring procedures over its use of COSTARS, including [e.g., periodic review of COSTARS procurement documentation, confirmation that COSTARS contracts were competitively awarded, and verification that applicable federal clauses are incorporated]. Documentation in the procurement files was not sufficient to clearly demonstrate how the underlying COSTARS procurement complied with the Uniform Guidance procurement standards for the specific federal award (e.g., basis for contractor selection, method of procurement relative to 2 CFR 200.320 thresholds, and required federal contract provisions). Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the value of the procurement transaction. Cooperative purchasing arrangements (such as state contracts or COSTARS) are not prohibited by the Uniform Guidance; however, the municipality must assume responsibility for the procurement and document how the cooperative contract satisfies the federal procurement requirements applicable to the award. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. The City has chosen to leverage the COSTARS cooperative purchasing program to improve efficiency and obtain favorable pricing. While the City has implemented monitoring over COSTARS (for example, reviewing selected COSTARS contract information and maintaining communication with the state regarding procurement practices), those procedures have not been formalized in the written procurement policy, and the related documentation is not consistently retained in the individual grant procurement files. As a result, the audit file did not contain clear, consistent evidence that the COSTARS contracts used for the tested transactions met all applicable Uniform Guidance procurement requirements. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. In addition, without documentation demonstrating clear, consistent evidence that COSTARS contracts used for purchases met all applicable Uniform Guidance procurement requirements, there is an increased risk of noncompliance which could result in unallowable costs being charged to the Federal awards. Repeat finding: Yes, finding 2023-002 Questioned costs known and likely: $184,512 known and $124,662 likely. Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows all Uniform Guidance procurement standards, especially regarding cooperating purchasing programs. View of Responsible Officials and Corrective Action Plan: Management agrees with this finding. Although procedures were previously established to ensure compliance with Uniform Guidance procurement standards, the finding recurred due to inconsistent implementation and insufficient monitoring of those procedures, particularly related to the use and documentation of cooperative purchasing programs.

Finding 2024-003: Significant Deficiency and Noncompliance over Procurement, Suspension, and Debarment Responsible Official’s Response and Corrective Action Plan We concur with the finding. The Foundation has an informal process of reviewing vendors and determining if they have been suspended or debarred. However, there is not a formal process where proper documentation such as screenshots of the search are saved. Due to the transition in the accounting department, we were not aware of these specific criteria at the time. We were notified of these requirements after the end of fiscal year 2024. To address these issues, a comprehensive process was implemented during fiscal year 2025 to ensure proper documentation and compliance with procurement regulations. This process will include: 1. Ensuring that all sole source vendor selections are properly documented and justified. 2. Verifying and maintaining records that confirm vendors are not debarred or suspended from doing business with the Federal Government before entering into contractual agreements. We are committed to improving our procedures and ensuring compliance with all applicable regulations moving forward. Planned Implementation Date of Corrective Action Plan June 2025 Person Responsible for Corrective Action Plan Natésha Johnson, Director of Finance and Administration Dr. Felecia Nave, President and Chief Executive Officer Luwanda Jenkins, Vice President of Partnerships and External Relation

Finding 2024-005 – Inadequate Procurement Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the InteriorFederal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Federal procurement standards require non-Federal entities to maintain records sufficient to detail the history of procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. Competitive procurement must follow the entity’s written procedures consistent with 2 CFR §§200.317-200.327, including:  Written procedures for procurement (§200.318(a)).  Full and open competition requirements (§200.319).  Methods of procurement (sealed bids, proposal requirements, and required documentation (§200.320).  Contract cost and price justification, (§200.324).  Suspension/debarment verification for covered transactions (§200.214; §200.213). Condition: During the audit period, the Entity did not retain sufficient procurement documentation for several contracts funded under the above Assistance Listings. Specifically, files lacked one or more of the following:  Evidence of the procurement method used.  Price or cost analysis.  Suspension/debarment checks for vendors where required.  Documentation of competition.  Conflict-of-interest attestations. Cause: Partnership for the Umpqua Rivers procurement procedures were not sufficiently detailed or consistently applied to federal purchases. No evidence of procedures or review for procurement or suspension / debarment was provided to auditors. Turnover and limited training on Uniform Guidance procurement standards contributed to the inconsistent file completeness. Effect or Potential Effect: Without complete procurement documentation, the Entity cannot demonstrate compliance with federal procurement requirements, increasing the risk of:  Noncompetitive awards or unreasonable prices.  Unallowable costs for the award requirements.  Potential disallowance or repayment of federal funds.  Findings in federal or pass-through monitoring and future audits. Questioned Cost: Yes, $902,496 related to expenditures that had no procurement support or detail. Context: During our audit, it was found that the Partnership for the Umpqua Rivers had experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to procurement, suspension or debarment procedures or processes. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Update Written Procurement Procedures o Incorporate Uniform Guidance thresholds and methods (§200.320), competition requirements (§200.319), and documentation expectations (history of procurement). o Embed steps for suspension / debarment checks and Appendix II Contract clauses.  Standardized Procurement Checklist o Pre-award checklist that verifies: method, competition evidence, cost/price analysis, conflict of interest attestations, SAM exclusion check, and required federal clauses. o Post -award checklist ensuring complete contract file (award memo, bid tab / evaluation, signed agreement, clause verification).  Cost/Price Analysis Guidance o Require documented price reasonableness for small purchases, formal cost or price analysis for larger or sole-source awards, per (§200.324).  Training & Accountability o Provide targeted training to procurement and program staff on 2 CFR §§200.317- 20.327 and Assistance Listing award conditions. o Implement supervisory pre-award review and periodic file audits. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a forma', written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file checklist before a contract is executed. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand H U D's procurement standards, including requirements forf ull and open competition and proper record-keeping. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto, COO, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by May 1, 2026.

2024-004 Procurement, Suspension and Debarment The Committee acknowledges that certain procurement procedures were not followed, leading to a finding of noncompliance. To remedy this, on July 1, 2025 we put new workflow controls in place within our new integrated accounting software. These workflows support compliance with our procurement policies and ensure all required supporting documentation, including forms for micro and small purchases, are secured and archived for capital purchases and grant expenditures. This will ensure that all procurement policies, which are in compliance with all FTA guidelines, are consistently followed.

FINDING 2024-002 – PROCUREMENT PROCEDURES-AMERICAN RESCUE PLAN (ARP) ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND (ESSER III) - ALN 84.425U-CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. This is a repeat finding 2023-002 from the prior fiscal year.-CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 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 involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance.-MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately.-District Officials Responsible for the Implementation of the Corrective Action Plan:-Aubrie Schnelle, Superintendent, and Austin Blauser, Business Manager