Corrective Action Plans

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31, 2025

Condition: Controls in place were not adequate to ensure the policy included appropriate procurement thresholds and methods. Planned Corrective Action: Management understands the importance of adhering to procurement thresholds and methods. Procurement policies and grant policies will be updated to include federal thresholds and methods to reflect federal Uniform Guidance. Contact person responsible for corrective action: Stephanie Cihon and Andy Vollmar Anticipated Completion Date: October 31,2025

The Auditor’s Office will work with the Commissioner’s Office and Prosecutor’s Office to implement the required policies.

Corrective Action Plan Federal Procurement Audit Finding 2023-002 Town’s Response: The Town concurs with the audit finding and has begun implementing the corrective actions outlined below. 1. Policy Alignment o Revise the Town’s Procurement Policy to explicitly state that federal Uniform Guidance procurement standards supersede state exemptions when federal funds are used. 2. Procedural Controls o Require a funding source review step in the requisition process: if any portion of funding is federal, staff must apply federal standards. o Incorporate a mandatory compliance checklist for all federally funded procurements, including documentation of cost/price analysis, vendor selection, and conflict of interest certifications. 3. Training & Awareness o Conduct annual training for the Procurement Manager. o Provide written desk guides / “quick reference sheets” for federal vs. state thresholds and documentation requirements. 4. Oversight & Monitoring o Director of Finance/Assistant Finance Director to review and approve all federal-funded procurement files prior to award. o Establish quarterly compliance monitoring of federal procurements, with results reported to the Town Manager via Monthly reports submitted. 5. System Enhancements o Explore Munis configuration options to flag federally funded accounts during requisition entry, ensuring the correct rules are applied.

This has been corrected with the new management. We have updated our poticies to have more oversight over procurement requirements and ensure we are getting the best prices or terms for the goods and services we purchase.

2023-008 – Procurement, Above Simple Acquisition (Significant Deficiency in Internal Controls over Compliance) Recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. 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. During the audit period, the College operated under procurement policies and procedures inherited from New Mexico State University (NMSU), as the College had recently separated from NMSU. The procedures were followed in good faith. Two College employees successfully completed Certified Procurement Officer (CPO) training in July 2021 and were recertified in March 2024. Another employee became certified in February 2024, and the College is having two additional employees participate in fiscal year 2025. This training demonstrates the College’s commitment to compliance and proper procurement practices. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy and Procedure Revision o The institution will revise its procurement policies and procedures to explicitly address purchases exceeding the Simplified Acquisition Threshold, incorporating:  Public solicitation and competitive bidding requirements  Cost or price analysis requirements per 2 CFR §200.324  Documentation of bid evaluations, vendor selection, and contract award  Use of federally compliant contract clauses (per 200.327 and Appendix II). • Training o Procurement, finance, and grant management staff will be trained on updated procedures, including:  Competitive procurement processes  Cost/price analysis methods  Documentation requirements • Procurement Checklist: o A standardized procurement checklist will be developed and required for all procurements above the Simplified Acquisition Threshold to ensure all federal steps are documented and reviewed. • Pre-Award Review Process o For all purchases above the Simplified Acquisition Threshold, the institution will implement a review and approval process involving procurement leadership and the grants compliance office before contract award. • Monitoring: o Annual internal monitoring will be conducted by the Procurement Office or Grants Compliance Office to ensure ongoing compliance with federal procurement requirements. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager

2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. 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. During the audit period, the College operated under procurement policies and procedures inherited from New Mexico State University (NMSU), as the College had recently separated from NMSU. The procedures were followed in good faith. Two College employees successfully completed Certified Procurement Officer (CPO) training in July 2021 and were recertified in March 2024. Another employee became certified in February 2024, and the College is having two additional employees participate in fiscal year 2025. This training demonstrates the College’s commitment to compliance and proper procurement practices. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy Update o The institution will revise its procurement policies to fully align with Uniform Guidance (2 CFR §200.320) requirements for small purchases. Policies will specify:  The dollar thresholds for small purchases  Requirements for obtaining at least two or more quotes, as applicable.  Acceptable methods of documenting quotes (written, online or verbal with notation).  Exceptions or special circumstances, if applicable under federal regulations. • Procedure Implementation o Detailed procedures and checklists will be developed to ensure consistent documentation of all small purchases under federal awards, including price comparisons and vendor justification. • Training o Procurement and grant personnel will receive training on the revised small purchase procedures to ensure understanding of documentation and compliance requirements. • Monitoring: o A periodic review process will be established to verify adherence to small purchase procurement requirements, with corrective actions taken if any deficiencies are identified. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager

While BREC currently does not have any federal expenses identified as unallowable costs applicable to this finding, a written SOP was recently 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: November 1, 2024 Responsible contact person: Don Johnson, Cheif Finance Officer

In regard to the village not having a written policy in place for the requirements outlined in the Code of Federal Regulations regarding the villages received Coronavirus funding, as previously stated the village does not routinely receive federal funds and was not aware at the time of having such a policy. The village is currently working with the village solicitor to rectify this issue. A new policy will be implemented to resolve this issue. – Mayor M. Shane Patrone

Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the Board of Education plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Statement of Concurrence or Nonconcurrence The City Board of Education concurs. Corrective Action management will review and enhance the procedures over the procurement and purchasing process, to be sure that all federal grant expenditures and contracts with vendors are performed properly in accordance with the Uniform Guidance. Name of Contact Person Natalie Forbes, Business Manager Projected Completion Date 6/30/2025

2023-003 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.

Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness 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. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. Condition: During fiscal year 2023, the Town could not provide evidence that they complied with the required procurement policies and procedures in place as it related to two of the expenses charged to the major program. Context: The Town purchased a new boiler for the School however the procurement documentation could not be located and the employee who would have overseen the project was unavailable to provide the supporting documentation. In addition, the Town could not locate or provide evidence that procurement procedures were followed when selecting an engineer for the Water Tank project. Questioned Costs: $71,500 related to the School Boiler Project and $170,163.70 related to the Water Tank Project. Cause: Directors used the Massachusetts procurement guidelines and not federal guidelines. Effect or Potential Effect: There is a risk that the amount 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: The Town of Hopedale should address the noncompliance and material weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: Kelly Grant, Assistant Town Administrator Estimated Completion Date: on going as grant and funds are still being used Action Taken: one person only responsible for making sure all federal and state procurement guidelines are met and followed.

Planned Corrective Action: Revise Financial Policies to require prior written approval from the Executive Director prior to entering into any agreement for expenditures between $10,000 and $49,999. If it is a sole source, written justification must be submitted and approved by the Executive Director prior to the execution of agreement. If multiple bids were obtained, these must also be submitted and the selected vendor approved by the Executive Director prior to the execution of agreement. Planned Implementation Date of Corrective Action: 2/5/2025 Person Responsible for Corrective Action: Director of Finance

Finding 2023-001 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs 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. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2023, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds. Questioned Costs: Unkown Cause: A Town State/Federal grants procedures manual that included proper procurement procedures did not exist until February 2023. Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable. Identification as a Repeat Finding: Yes, finding number 2022-002 Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Managements Response: We acknowledge the audit finding related to non-compliance with the required procurement policies and procedures for procurements exceeding the State and Federal thresholds during Fiscal Year 2023. The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326. We are pleased to report that we believe to have addressed this issue in Fiscal Year 2024 to ensure compliance with the procurement policies and procedures, as required by both State and Federal threshold. Responsible for Corrective Plan: School Business Manager Estimated Completion Date: Fiscal Year 2024 Action Taken: The Town and Schools have adopted Acushnet’s Federal Grant Procedures Manual (February 2023). This manual ensures that all procurements are conducted in accordance with the relevant Federal and State procurement standards, specifically the requirements outlined in 2 CFR sections 200.318 through 200.326. We are pleased to report that we have taken steps to address this issue and believe we have successfully ensured compliance with these procurement policies and procedures.

Finding Number: 2023‐002 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: • Mandatory documentation of quotes for applicable procurements • Verification and documentation of suspension and debarment checks for all covered transactions • Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification: The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

Views of Responsible Officials and Planned Corrective Actions: Agree with recommendation. A draft procurement policy has been prepared. It will be modified to ensure compliance with procurement of property or services required under a Federal award. Employees with procurement responsibilities will be required to follow the policy.

Response to the Schedule of Findings and Questioned Costs by Schriver Carmona, CPA on Audited Financial Statements of Beasley Brown Community Development Corporation for the Year Ended December 31, 2023 Finding #2023-001: BBCDC was unaware of the compliance requirement, and did not follow its written procurement policy, which resulted in $324,000 of questionable costs that caused it to not meet the procurement requirements for Congressionally Funded Community Projects. Action: At its Board of Directors meeting March 17, 2025, the Beasley Brown Community Development Corporation took the following action: It voted to revise its procurement policy to include a section entitled "Procurement Policy Procedures applicable to Non-Federal Entities.” This section will include all requirements stated in CFR 200.318 – 200.326. Procedures will require documented evidence of all proposed purchases and contracts under this section per CFR 200.318 – CFR 326 and approval by the Board of Directors or designated persons. The Board also moved that periodic training on CFR 200.318 – CFR 200.326 must be provided to the Board of Directors and other designated persons. Rev. Dr. Melvin Wilson, Jr., Chair – Board of Directors, will be responsible for ensuring the corrective action plan is implemented. The corrective action was implemented beginning March 18, 2025.

Schedule of Corrective Action Plan For the Year Ended December 31, 2023 Finding: 2023-01 Significant Deficiency and compliance over Procurement and Suspension and Debarment. Responsible Official’s Response and Corrective Action Plan Rising for Justice, Inc. (RFJ) implemented a corrective action plan effective October 1, 2023. RFJ updated its Office Operations Manual to include a process for verifying that vendors are not debarred from doing business using federal funding, by reviewing the federal System for Award Management (SAM) at www.sam.gov. Documentation of vendor verification and procurement compliance is maintained in the vendor files and reviewed with final approval by the Executive Director. Procurement Policy Summary (Effective October 1, 2023) RFJ adopted a comprehensive Procurement Policy to ensure that all purchases and contracts are executed through an open, fair, documented, and competitive process. Key provisions include: •Applicability: The policy covers all purchases and contracts regardless of funding source or total cost,unless specifically exempted. •Allowability: Expenditures must be necessary, reasonable, allocable, and documented. •Conflict of Interest: All staff must comply with RFJ’s Conflict of Interest Policy; no personal gain fromvendor relationships is permitted. •Authorization: The Executive Director approves contracts per policy thresholds. Delegation ofauthority must be in writing. •Competition Requirements: oUnder $10,000: No formal bidding required; professional judgment applies. o$10,001–$25,000: At least two quotes required. oOver $25,000: At least three quotes and/or RFPs. •Sole Source & Emergency Purchases: Allowed with proper documentation. •Federal Debarment Check: Vendors for federal contracts over $25,000 must be verified throughwww.sam.gov. Conclusion: All the vendors listed in the auditor’s findings for FY23 were selected before the corrective action was taken in October 2023. Person Responsible for Corrective Action Plan Chijioke Akamigbo, Executive Director April 15, 2025

Finding 2023-007: Significant Deficiency, Procurement and Noncompliance Finding – Procurement – Internal Control over Procurement Finding: SPED/Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases-Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. The DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, the City did not follow their own procurement policy requiring two quotes for a micro-purchase expenditure, three quotes for a small purchase expenditure and advertising for bids publicly for the large >$5,000 purchase expenditures. They only obtained one quote for each expenditure for micro and small purchases, and they did not use a public bid process for expenditures over $5,000. Corrective Action Taken or Planned: Danbury Public Schools (DPS) will begin reviewing the procurement policies that are in place in order to ensure they are in accordance with all compliance requirements set forth by any grants that DPS participates in. A memorandum will be issued summarizing procurement policy features. Lastly, training will be conducted with both the department and the finance team to review the policies and ensure understanding.

State and Local Fiscal Recovery Funds - Procurement Recommendation: We recommend that the District reviews its procedures and controls over procurement for the Coronavirus State and Local Fiscal Recovery Funds program to ensure it is following federal guidance and internal policies over the procurement process and documenting the appropriate method and history of the transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken 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. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will endeavor to make sure the FEMA files are updated and complete after FEMA reimbursement.

Federal Awards Finding 2023-004: Noncompliance with Federal Award Program Requirements Finding/Condition We noted the following deficiencies: 1. The Rancheria was unable to provide supporting documentation for the allocation of expenditures reported for federal award programs. 2. The Rancheria was unable to provide actual time records for employees, supporting payroll expenditures claimed as expenditures for federal award programs. 3. The Rancheria was unable to provide documentation to show that it complied with the procurement standards required in 2 CFR 200.318. Additionally, the Rancheria does not have a procurement policy which complies with those standards. Planned Corrective Action The Rancheria will be updating and implementing policies and procedures to address these risks. Anticipated Completion Date December 31, 2024

Program 66.958 Water Infrastructure Finance and Innovation Award No: WIFIA-N18147WI Award Year: 2023 Finding 2023-001: Procurement policy and related contract Repeat finding of 2022-001Waukesha Water utility management has worked closely with WIFIA to craft contracts that include all necessary language prior to releasing RFPs for construction contracts. WIFIA was presented all service contracts to review prior to reimbursements received in fiscal year 2023. The finance department is working to update the procurement policy to ensure necessary federal language is included. The finance department will also work with service contractors to execute contract addendums

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension and Debarment Summary of Finding: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. INDIANA STATE BOARD OF ACCOUNTS 41 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation could not provide supporting documentation that an adequate number of price or rate quotations was obtained to ensure full and open competition for two vendors procured under the small purchase threshold. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The procurement method used to purchase equipment costing over $10,000 will be documented and archived with the purchase order. Anticipated Completion Date: July 31, 2024

Finding 2023-003 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town of Coventry and the Coventry Public Schools will review the current purchasing policies and update them to make sure that the Town and School Department is following the criteria as set out in the 2 CFR sections 200.303 and 200.318 through 200.326. The policy will then be updated and communicated to all personnel involved in the procurement process. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025