Corrective Action Plans

Audit period: The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule of expenditures of federal awards. Finding 2024-001 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Criteria: 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. Condition and Context: During our testing as it related to compliance with procurement we noted that an expense for engineering services for the Waste Water Treatment Assessment services charged to the major program would have required a formal bidding process as the project exceeded the simplified acquisition threshold. The Town had selected the engineering company for “On Call” engineering services as it related to the DPW through a request for qualifications process. The contract does include as part of the services to be provided Waste Water Treatment Assessment services. However, the contract is not specific to federally funded projects. The Town of Medfield had submitted the request for qualifications documentation as well as the executed contracted for “On Call” services to both the Town’s consulting service and the pass through entity for approval of the Waste Water Treatment Assessment. The pass through entity and the pass through entities Auditors did not have any concerns with the request for qualifications as it relates to the Waste Water Treatment Assessment project. Questioned Costs: $40,500 Cause: Based on the judgement of the pass through entity (Norfolk County) and their auditors, the Town was approved to procure engineering services for the Waste Water Treatment Assessment as part of a larger “On Call” services contract. The Town did select the contractor through a competitive request for qualifications process, but did not initiate a separate procurement for the sub-project. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: Going forward, the Town of Medfield should consider a separate bidding process for expenses related to federal grant funds. Responsible for Corrective Plan: Contact Person: Kristine Trierweiler, Town Administrator Estimated Completion Date: April 30th, 2025 Action Taken: On an ongoing basis, the Town will initiate separate procurements for projects covered under federal grants.

We now have a better understanding of what is considered public works versus equipment. Public Works bids will be let for all items that fall under the Public Works definition. We have since conducted internal training on Public Works definitions.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COMPREHENSIVE LITERACY DEVELOPMENT, FEDERAL ALN 84.371 2024-001 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Aurora Charter School (the School) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the comprehensive literacy development federal program. During our audit, we noted the School did not have sufficient controls in place within its Comprehensive Literacy Development federal program to ensure compliance with federal procurement requirements related to suspension and debarment and to assure that it was not contracting for goods or services with parties that are suspendded 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 School has updated its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The updated procedures include steps so that School personnel are following the requirements of the Uniform Guidance related to suspension and debarment requirements including maininging appropriate documentation. Official Responsible – The School's Executive Director, Matthew Cisewski. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The School agrees with this finding. Plan to Monitor – The School’s Executive Director, Matthew Cisewski, will monitor the updating of policies and procedures related to suspension and debarment to ensure these requirements are complied with in the future.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – (ALN 10.553 AND 10.555) 2024-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal program. During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster funds federal programs to ensure 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 Academy is in the process of reviewing 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 review of procedures will also include steps to assure that Academy personnel are following the requirements of the Uniform Guidance related to methods of procurement, and suspension and debarment and maintaining appropriate documentation. Official Responsible – The Academy’s Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures areupdated and in place to ensure compliance with procurement, and suspension and debarment requirements.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Finley School District No. 53 September 1, 2023, through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 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 District did not have adequate internal controls to ensure compliance with procurement requirements related to piggybacking. Name, address, and telephone of District contact person: Terri McGaughey, Business Manager 224606 E Game Farm Rd, Kennewick, WA 99337 (509) 586-3217 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 Finley School District has put in place internal controls to ensure compliance with procurement requirements related to piggybacking: The Food Service Director will compare invoices to the monthly price list to ensure contract pricing is used and initial invoices once reviewed. If there are discrepancies, the Food Service Director will contact the vendor for corrections. Quarterly, the Business Manager will select a sample of invoices to review for compliance. Anticipated date to complete the corrective action: May 1, 2025

Views of responsible officials and planned corrective actions: Management agrees with the finding consider their procurement policy to align with the requirements of 2 CFR 200.318 and are expecting to be a low-risk auditee during the 2025 fiscal year.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend that management review the procurement, suspension and debarment requirements for federal programs as well as the organization's policies related to these requirements. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy review & update: Completed a comprehensive review of federal procurement, suspension and debarment requirements and revised the organization’s policies to align with those standards. Vendor assessment: Screened all active vendors against the SAM .gov exclusion list; documented results and removed or remediated any non-compliant relationships. Training & communication: Held mandatory training for procurement, finance and compliance teams on the updated policies and federal requirements. Ongoing monitoring: Established process to communicate exclusions to senior management to ensure continuous adherence. Name of the contact person responsible for corrective action: Christine Simiriglia, President & CEO Planned completion date for corrective action plan: June 30, 2025

Finding 2024‐007: Procurement and Suspension and Debarment Federal Agency Name: U.S. Department of Health and Human Services Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Federal Financial Assistance Listing Number: 93.829 Finding Summary: The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. In addition, the Organization entered into a contract with a vendor for services without obtaining quotes from other vendors. Responsible Individuals: Joshua Duame, Fractional CFO Corrective Action Plan: Management agrees with the finding. Management will implement a written procurement, suspension and debarment policy that meets Federal, State, local, and tribal laws and regulations. We also recommend that management review this policy regularly to confirm that it meets the requirements and that all transactions follow this policy. Anticipated Completion Date: 6/1/2025

Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed. ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies and internal controls under the ARPA (American Rescue Plan Act) contract. To address this issue, the Interim Executive Director and the Financial Team have taken immediate steps to strengthen compliance and oversight. Specifically: Oversight and Delegation: ACLAMO and its Board of Directors have agreed to hire a full-time finance director for the organization. In conjunction with the ongoing designated Construction Manager, these individuals will ensure that all procurement and financial reporting actions are in accordance with internal policies and federal guidelines stated in the contract, and that project documentation is compiled and securely stored in a timely manner for audit readiness. Infrastructure Committee Procedures: The Interim Executive Director, alongside other members of ACLAMO management, are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve the designated Construction Manager to monitor compliance with standardized procedures & reporting throughout the project, that meeting minutes are properly recorded by the grantor's requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. Training and Capacity Building: To ensure consistent application of procurement policies, ACLAMO will provide and require mandatory training for all staff involved in procurement and contract management. Training will cover federal procurement standards, internal procedures, and documentation protocols. Policy Review and Update: As part of our continuous improvement efforts, ACLAMO will conduct a comprehensive review of its procurement policy to ensure it fully aligns with federal Uniform Guidance (2 CFR 200) and make updates where needed. The revised policy will be disseminated to all relevant personnel. ACLAMO is committed to strengthening internal controls, ensuring transparency, and maintaining full compliance with all contractual and federal requirements.

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.