Corrective Action Plans

FINDING 2024-010 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement - Small Purchases The school corporation will follow all Federal Requirements for small purchase procedures including obtaining price or rate quotations from an adequate number of qualified sources. We will document the procurement method we are using and attach supporting documentation for rate and price quotes by source. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, the school corporation will verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. All purchases $25,000 or greater will involve the following process - (1) checking SAM.gov to see if there are any exclusions, (2) require Vendor supply certification that they have not been suspended or debarred OR clause will be added to agreement or contract signed by Vendor as certification. Anticipated Completion Date: December 1, 2025

SPECIAL EDUCATION CLUSTER – PROCUREMENT U.S. Department of Education Special Education Cluster Assistance Listing Number: 84.027 & 84.173 Passed Through Minnesota Department of Education Pass Through Number: H027A220087 Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. 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 educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025 and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – PROCUREMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 93.600 and 93.558 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. 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 educating all the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Views of Auditee and Corrective Actions: GDOE disagrees with the finding. GDOE does allow for vendors to provide quotes for brand name or equal products. In this case, the substitute product offered was not equal to the product GDOE was soliciting. The end user provided justification that the substitute product did not meet the needs or specifications requested.

Views of Auditee and Corrective Actions: GDOE disagrees with the finding. Auditors cited the lack of procurement policies that meet 2 CFR 200.324(a), but did not find any evidence that GDOE did not comply with procurement regulations.

VFC is in the process of updating its entire accounting policies and procedures manual, which includes the procurement policy. This policy will be written to comply with all federal and state statutes and regulations. The expected completion date is December 31, 2025.

Finding Title: Noncompliance with Procurement Standards – Professional Services Responsible Person: Grace Kim, CFO Corrective Action Plan: The Foundation acknowledges the auditor’s finding that procurement standards were not followed when the attorney for this project was hired. Management did not anticipate the need to apply procurement requirements to legal services at the time of engagement. Management recognizes the importance of procurement regulations as a core internal control responsibility and will implement the following corrective actions: The organization will formalize and strengthen its procurement procedures to ensure compliance with applicable requirements. Specifically: 1. A written procurement policy will be developed and adopted that clearly defines competitive quote and documentation requirements for all goods and services, including professional services such as legal counsel. 2. The policy will specify thresholds requiring multiple price quotes or justification for sole-source procurement. 3. Management will require documentation on price comparisons or written justification prior to executing contracts or engagement letters for professional services. 4. Staff involved in procurement and contract approvals will be trained on the new procurement policy and compliance requirements. Anticipated Completion Date: January 1, 2026

Conditions – During 2024, the Organization did not maintain documentation related to how they chose a contractor for construction projects such as how they chose contractors to get bids from, how many bids were obtained, detailed bid information, and what factors they considered in choosing a contractor. No documentation exists showing considerations of price, contingencies, length of contract, and perceived risks. Recommendation – We recommend maintaining documentation supporting the compliance with federal regulations for all expenditures of federal funds. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the finding and appreciates the auditor’s recommendation. The Organization exceeded the Single Audit threshold for the first time in 2024 due to a one-time coronavirus-related grant. As a result, management was not fully aware of the federal procurement documentation requirements applicable to these funds. To address this matter, management has implemented procedures to ensure that procurement documentation supporting compliance with federal regulations is maintained for all federal expenditures. These procedures include staff training on federal grant compliance requirements, enhanced oversight of procurement activities, and the use of standardized documentation and retention practices. Management believes these corrective actions will mitigate the risk of future noncompliance and strengthen overall federal grant administration.

Conditions – During 2024, the Organization did not have a written procurement policy. Recommendation – We recommend that the Organization develop and implement a written procurement policy. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the finding and appreciates the auditor’s recommendation. The Organization exceeded the Single Audit threshold for the first time in 2024 due to a one-time coronavirus-related grant. As a result, management was not fully aware of the federal procurement documentation requirements applicable to these funds. To address this matter, management has implemented procedures to ensure that procurement documentation supporting compliance with federal regulations is maintained for all federal expenditures. These procedures include staff training on federal grant compliance requirements, enhanced oversight of procurement activities, and the use of standardized documentation and retention practices. Management believes these corrective actions will mitigate the risk of future noncompliance and strengthen overall federal grant administration.

Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all department heads to ensure proper compliance in the utilization and disbursement of federal funds.

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timing, the earliest possible implementation of corrective action is in FY 26. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This policy, which includes a Conflict of Interest section, was updated to reflect a decrease of the micro-purchase threshold from $50,000 to $10,000, clarifies that the SAM.gov check for suspension and debarment will occur prior to contract execution with the contractor, and the SAM.gov check will be documented with the date it was conducted. The updated CIF Procurement Policies & Procedures will be approved by the Board of Directors.

Corrective action plan to address finding 2024-003 - No written procurement policy. The following steps will be taken to bring the Borough into compliance. 1. A policy was developed by the manager 2. The policy was shared with Borough Council members in November. 3. At the Borough council meeting (12/10/2025) the policy was formally presented for adoption. 4. The policy was effective upon completion of the vote at the December meeting.

Prospectively, Historic South will review best practices related to the contract awarding process and formal contracting arrangements for construction work. In addition, Historic South will implement policies of: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work

The Village of Whitehouse will work with our outside Engineers to ensure that all compliance items are being addressed in all initial meetings for projects using Federal Funds. This will ensure that all policies and procedures are put into place prior to the start of the project. The Village will seek out training on federal procurement compliance requirements.

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement and suspension and debarment requirements, and it did not comply with federal suspension and debarment requirements.Name, address, and telephone of District contact person: Kristina Ribellia 903 W. 3rd Ave. Moses Lake, WA 98837 509-765-9618 Corrective action the auditee plans to take in response to the finding: The District agrees with the finding. At the time of contracting, staff were unaware of the specific federal verification requirement under 2 CFR 180.220 and 2 CFR 200.213. Immediately upon notification, the District verified that the contractor was not suspended or debarred, and no questioned costs were identified. The District has developed formal written procurement procedures consistent with 2 CFR 200.318–200.327 and state procurement laws. These procedures will be presented to the Board of Supervisors for review and adoption at an upcoming public meeting and will be incorporated into the District’s Administrative and Operations Procedures Manual once approved. In addition, the District has drafted a Suspension and Debarment Verification Procedure, which will require verification of all contractors receiving $25,000 or more in federal funds through SAM.gov prior to contract execution. Documentation of this verification will be retained for all federally funded agreements once the procedure is adopted. The District appreciates the SAO’s constructive recommendations and remains committed to implementing these new policies promptly. We are dedicated to continuous improvement in our policies, processes, and internal controls to ensure ongoing compliance and transparency in the administration of public funds. Anticipated date to complete the corrective action: December 2025

Finding: Material weakness in internal control over procurement policies Questioned costs: ALN 81:113 ($31,120) ALN 19.901 ($15,000) Corrective action: While PFI accepts the finding and the rationale for identifying questioned costs based on Uniformed Guidance (UG) requirements for documentation regarding competitive bidding and contract types, it believes there is adequate documentation to justify incurred costs. PFI will update its procurement policy guidelines to reflect current UG requirements to include acquisition thresholds and competitive bidding procedures. Completion Date: February 1, 2026 Responsible Individual: Executive Director

The District’s Business Manager will obtain quotes/bids when necessary.

FA 2024-001 Improve Controls over Procurement Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19 - 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 245GA324N1199 (Year: 2024) 245GA324L1603 (Year: 2024) 245GA324l1603 (Year: 2024) $5,380.74 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: Implement a standardized procurement checklist that must be completed. Procurements will require two levels of review (program level review by child nutrition staff and District level) to confirm compliance before processing payments. District will provide staff training to ensure federal procurement regulations, district procurement policies along with documentation and recordkeeping requirements are being met. The finance department will conduct quarterly internal reviews of Child Nutrition expenditures to verify compliance. Estimated Completion Date: November 10, 2025 Contact Person: Jon Erik Jones, Superintendent Telephone: 229.321-1487 Email:jones@quitman.ki2.ga.us

Condition: ALC has not implemented all policies and procedures required by 2 CFR Part 200, specifically for cash management, allowability of costs, procurement, compensation, and fringe benefits. Planned Corrective Action: The American Loggers Council will develop written policies and procedures to comply with 2 CFR Part 200, specifically for cash management, allowability of costs and procurement. Policies and procedures related to compensation and fringe benefits currently do not apply to the Organization because they do not have any employees. These policies and procedures will be reviewed and approved by the executive director and executive committee. Contact Person: Scott Dane Anticipated Date of Completion: December 2025

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Woodland January 1, 2024, through December 31, 2024 This schedule presents the corrective action the district plans to take for the findings included in this report, in accordance with Title 2 of the U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The Port did not have adequate internal controls and did not comply with federal procurement and suspension and debarment requirements. Name, address, and telephone of District contact person: Debbie Karlsson, Interim Deputy Director/Finance Administrator 1608 Guild Road Woodland, WA 98674 (360) 225-6555 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement.) The Port will implement new procedures that conform to the Port’s existing policy to verify suspension-and-debarment status of all applicable contractors in the future. This includes performing verification, modifying future contract language, and retaining evidence of verification. The Port is currently restructuring staffing and work functions, which will provide more clarity to staff on their specific roles and responsibilities. This will also allow the Port to make sure staff have sufficient training to carry out those responsibilities in accordance with the updated internal controls, including compliance with the Build America, Buy America Act. Anticipated date to complete the corrective action: March 31, 2026

Corrective Action Plan – Finding 2024-002 – Reporting Town of Van Buren – CFDA 21.027 – Coronavirus State and Local Fiscal Recovery Funds Audit Period: Fiscal Year Ended June 30, 2024 Views of Responsible Officials: The Town of Van Buren acknowledges the auditor’s finding regarding the lack of documentation for quarterly performance reports required under 2 CFR 200.329. However, it is important to clarify that, during the grant period, the Town communicated with Efficiency Maine Trust regarding these expectations. Efficiency Maine Trust, as the pass-through entity, confirmed that such federal performance reporting was not required to be submitted back to them by the Town as part of their grant process. Additionally, upon review of the contract provided to the Town, it was noted that the Town was inaccurately listed as a "co-recipient" of the SLFRF (State and Local Fiscal Recovery Funds). After multiple discussions with representatives from the U.S. Department of the Treasury – SLFRF team, it was confirmed that this designation was erroneous. The Town of Van Buren was not a co-recipient but rather a beneficiary of the ARPA funds administered by Efficiency Maine Trust. As a beneficiary, the Town was not responsible for direct federal reporting to Treasury, and this misclassification contributed to the confusion regarding reporting responsibilities. Corrective Action Plan: To prevent similar issues in the future and ensure full compliance with all federal award terms and conditions, the Town will implement the following measures: 1. Clarification of Role: All future grant agreements will be reviewed to confirm whether the Town is operating as a recipient, subrecipient, or beneficiary, and appropriate obligations will be documented. 2. Federal Reporting Procedures: For grants that include federal reporting obligations, the Town will establish an internal checklist outlining the specific reporting requirements and due dates upon award acceptance. 3. Training and Compliance: Staff responsible for grant administration will receive annual training on 2 CFR Part 200 requirements, including those relating to reporting and roles under federal awards. 4. Documentation and Recordkeeping: All communications with pass-through entities and federal agencies relating to grant requirements will be documented and retained as part of the grant file. By implementing these internal control enhancements, the Town aims to prevent future findings and ensure clarity in grant compliance responsibilities.

Corrective Action Plan – Finding 2024-002 – Reporting Town of Van Buren – CFDA 21.027 – Coronavirus State and Local Fiscal Recovery Funds Audit Period: Fiscal Year Ended June 30, 2024 Views of Responsible Officials: The Town of Van Buren acknowledges the auditor’s finding regarding the lack of documentation for quarterly performance reports required under 2 CFR 200.329. However, it is important to clarify that, during the grant period, the Town communicated with Efficiency Maine Trust regarding these expectations. Efficiency Maine Trust, as the pass-through entity, confirmed that such federal performance reporting was not required to be submitted back to them by the Town as part of their grant process. Additionally, upon review of the contract provided to the Town, it was noted that the Town was inaccurately listed as a "co-recipient" of the SLFRF (State and Local Fiscal Recovery Funds). After multiple discussions with representatives from the U.S. Department of the Treasury – SLFRF team, it was confirmed that this designation was erroneous. The Town of Van Buren was not a co-recipient but rather a beneficiary of the ARPA funds administered by Efficiency Maine Trust. As a beneficiary, the Town was not responsible for direct federal reporting to Treasury, and this misclassification contributed to the confusion regarding reporting responsibilities. Corrective Action Plan: To prevent similar issues in the future and ensure full compliance with all federal award terms and conditions, the Town will implement the following measures: 1. Clarification of Role: All future grant agreements will be reviewed to confirm whether the Town is operating as a recipient, subrecipient, or beneficiary, and appropriate obligations will be documented. 2. Federal Reporting Procedures: For grants that include federal reporting obligations, the Town will establish an internal checklist outlining the specific reporting requirements and due dates upon award acceptance. 3. Training and Compliance: Staff responsible for grant administration will receive annual training on 2 CFR Part 200 requirements, including those relating to reporting and roles under federal awards. 4. Documentation and Recordkeeping: All communications with pass-through entities and federal agencies relating to grant requirements will be documented and retained as part of the grant file. By implementing these internal control enhancements, the Town aims to prevent future findings and ensure clarity in grant compliance responsibilities.

Finding #SA2024-004 Compliance with Procurement Requirements Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: A-00216-01 • Name(s) of the contact person: Melissa Munoz, Interim Assistant Finance Director • Corrective Action Plan: Staff recognize that importance of following the current purchasing policy and retaining the proper records. Finance staff are working with the departments to ensure the documentation is being attached to all purchases and retained electronically. Critical positions that were vacant within the department have been filled, which has helped alleviate some of these issues. The City is in the development phase of the purchasing policy and is actively working with a consultant on the policy. This policy will be partially implemented in Fiscal Year 2026. • Anticipated Completion Date: 6/30/2026

In our audit findings there was noted $555,000 in bids awarded were not properly advertised. There was an advertisement for a pre-bid meeting for the projects. The projects were the removal of blockages on Rough River with money received from NRCS for that purpose. The intention was for the ad to say the projects were open and that bids were to be received by a certain date. The ad was improperly ran but not intentionally. We will double check all items going to bid. If an item is sent by any department it will be double checked at the Judge Executive's office. If it originates here it will be double checked by the treasurer's office.

Finding ref number: 2024-001 Finding captions: The district did not have adequate internal controls ensuring accurate reporting of its financial statements. Name, address, and telephone of District contact person: Erick Brittain, Fire Chief PO Box 1449, Soap Lake, WA 98851 (509) 246-0321 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). 1. Develop and implement Written Policies and Procedures- The District will immediately develop formal, written internal control policies and procedures specific to financial reporting. This will include a robust internal review process to ensure all financial statements are accurate, properly supported and classified correctly prior to submission. Assigned to: Fire Chief and Administrative Assistant 2. Mandatory Financial Reporting Training: The Administrative Assistant and Fire Chief will attend ongoing training on Budgeting, Accounting and Reporting System (BARS) to gain a comprehensive understanding of proper financial reporting requirements and principals Assigned to: Fire Chief and Administrative Assistant 3. Cross Training and Segregation of Duties: The District will establish clear segregation of duties to ensure no single employee has control over all steps of a financial transaction or reporting process. The Administrative Assistant and Fire Chief will be cross trained to provide independent secondary review of the financial statements as well as obtaining Board of Commissioner Approval. Assigned to: Fire Chief and Administrative Assistant. 4. Contract with a third-party scheduling platform: The District will contract with a third-party vendor to accurately track employee time off in accordance with Grant County Fire District #7 paid time off policy. Assigned to: Fire Chief. Anticipated date to complete the corrective action: Ongoing/ December 31st 2025 Finding ref number: 2024-002 Finding captions: The district did not have adequate controls and did not comply with federal suspension, debarment and procurement requirements Name, address, and telephone of District contact person: Erick Brittain, Fire Chief PO Box 1449, Soap Lake, WA 98851 (509) 246-0321 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). 1. Develop and Implement Comprehensive Procurement and Public Works Policies: The District will immediately develop and adopt robust written procurement and public works policies and procedures. These policies will ensure compliance with both federal regulations and Washington state law (RCW). The policies will include detailed procedures for: ○ Vendor and Subcontractor Vetting: Incorporating explicit steps for checking potential vendors against the federal System for Award Management (SAM) database to ensure they are not suspended or debarred. This process will apply to all federally funded procurements, as well as any other procurements exceeding the federal threshold of $25,000 paid with federal funds. ○ Competitive Bidding: Establishing clear thresholds for purchases and public works projects requiring minimal, informal, or formal competitive bidding, in line with state guidelines. ○ Public Works Requirements: Mandating compliance with prevailing wage requirements and incorporating bonding and retainage rules for all public works projects. ○ Documentation: Requiring detailed record-keeping for all procurement activities, including bids, vendor evaluations, and justification for contract awards. ○ Contract Clauses: Including a standard contract clause affirming vendor understanding and compliance with federal debarment and suspension requirements. ○ Policy Approval: Submitting the draft policies for review and adoption by the district’s governing body. ○ Assigned to: Fire Chief and Administrative Assistant. 2. Conduct Staff Training: All relevant staff, particularly the Fire Chief and Administrative Assistant, will undergo mandatory training on the new policies and procedures. Training will cover the correct application of procurement rules, the importance of federal suspension and debarment checks, and proper documentation procedures. ○ Assigned to: Fire Chief. 3. Implement Management Review and Oversight: The Fire Chief will conduct and document a review of all procurement and public works transactions to ensure compliance with the newly adopted policies before any contract is finalized, or a purchase order is issued. ○ Assigned to: Fire Chief. 4. Establish Periodic Compliance Self-Assessment: The District will perform annual self-assessments of its procurement process to identify and correct any control weaknesses and ensure ongoing compliance with federal and state regulations. ○ Assigned to: Fire Chief Anticipated date to complete the corrective action: Ongoing/ December 31st, 2025.