Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: Following ICMEC's internal procurement policy and based on the Federal program’s technical specifications, ICMEC contracted an independent third party to select the recommended equipment and services using Florida Department of Law Enforcement protocols for procuring equipment.

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022 - 8/30/2023 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Finding Summary: As part of the audit, Eide Bailly LLP identified that the formally documented policy did not include many of the necessary procurement provisions prior to its revision in February 2024. Provisions include a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. In addition, current controls are to be documented to provide for a proper audit trail. Responsible Individual: Chief Financial Officer Corrective Action Plan: The policy was updated in February 2024 to include all federal requirements regarding procurement controls and suspension and debarment controls as proposed by the auditors. Completion Date: February 2024

Corrective Action Plan Finding 2023-002 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.

Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend the Agency's procurement policy is updated to reflect the current federal guidelines and that policies and procedures are implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Ventures is in the process of evaluating and updating our procurement policy and expects it to be complete by year end. We have already started making sure necessary documents needed for RFQs and RFPs are kept in a restricted access folder along with the methodologies and tabulations for the final decisions. The Executive Director will approve all final decisions on RFPs and RFQs. Name(s) of the contact person(s) responsible for corrective action: Theo Everheart and Monique Valenzuela Planned completion date for corrective action plan: 12/31/2024

Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.

Finding 2023-005 - Procurement Repeat Finding- See Finding 2022-007 Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. Action Taken: The City does follow Uniform Guidance procurement standards. In this instance, a vendor was selected under an emergency contract basis utilizing our waiver of bids policy. The entire country was awarded ARPA funds with water and sewer lining replacement being an allowable use of these funds. Due to the fact that there are a very limited number of vendors who provide this service, and the fact that there would be a significant number of municipalities seeking this service with the influx of ARPA dollars, as well as the fact that due to supply and demand, the cost for these services were escalating rapidly, the City wanted to be one of the first to engage with a contractor in order to secure a vendor in a timely manner before we would be unable to do so since the projects are long term projects and there was a time limit on when this money would need to be spent. Therefore, we knew it would not be possible to conduct our own bid. We chose a vendor off the COSTARS contract. I have attached a copy of the ordinance where we explained to Council our concern for our securing a vendor and our need to act quickly, which is why we originally initiated the purchase from City funds, before ARPA funds were distributed, and then replaced the City funds with ARPA funds once they were received.

Management will review their current procurement policies and make any necessary changes to update the policies to be compliant with 2 CFR Sections 200.138 – 300.327. We anticipate that the corrective action will be completed within 12 months.

Formula Grants for Rural Area and Tribal Transit Program Federal Assistance Listing #20.509 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 and state requirements for procurement. The Organization should ensure documents are retained to support whether procurement policies were followed for vendors procured in years past. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review the procurement standards as well as ensure documents are retained to support whether procurement policies were followed. Name(s) of the contact person(s) responsible for corrective action: Denise DeMartelaere, Co-Director of Finance Planned completion date for corrective action plan: 12/31/2025

Finding 2023-002: Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the Axon contract totaling $651,922 for the year ended December 31, 2023 followed formal procurement procedures. The Axon contract exceeds the Uniform Guidance formal procurement threshold but was done through cooperative purchasing. In addition, in accordance with the Uniform Guidance, a purchase price from a cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. 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. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. The City relied upon vendors preapproved by the Commonwealth of Pennsylvania’s General Services Administration (GSA). These vendors were considered preapproved based on the Commonwealth’s own use of cooperative purchasing programs. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat finding: No Questioned costs: Unknown 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. Management has established procedures to ensure that our purchasing policy follows all Uniform Guidance procurement standards, especially regarding cooperating purchasing programs.

Finding Number: 2023-004 Finding Title: Procurement, Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Kris Vipond, Assistant Finance Director Corrective Action Planned: Directors in departments receiving federal funding will document the history of procurement transactions, including contract selection and rationale, in accordance with federal regulations. They will also verify vendors are not debarred or suspended, or that other exclusions apply prior to entering into contracts and will maintain the appropriate documentation. In addition, they will work with other internal County departments that may purchase on their behalf to document and verify in a similar manner. Anticipated Completion Date: 12/31/2025

U.S Department of Treasury COVID 19 – Coronavirus State and Local Fisal Recovery Funds – 21.027 Management’s Response: The amount of the expense with this vendor was below $5,000 for three separate invoices and events. The Unified Government’s purchasing policy does not require competitive quotes for purchases under $5,000. However, we understand that we should be viewing these expenses in the aggregate not as individual transactions. We will work with the department to ensure these are competitively procured going forward. Views of Responsible Officials and Corrective Action: Departments have been informed of the procurement requirements and the procurement policy will be adhered to on a go forward basis. Management will ensure this is addressed by December 31, 2025. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Finding 2023‐002 Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Corrective Action Plan: We will revise our procurement policy to include thresholds for micro‐purchases and small acquisitions and include a policy that defines formal procurement methods that vendors will be required to adhere to. This is to remain in compliance with 2 CFR 200.318 through 200.320. Additionally, we will state that vendors will be required to be curated for disbarment and suspension via SAM.gov database lookups. Anticipated Completion Date: December 31, 2024. Name(s) of the Contact Person(s) Responsible for Corrective Action: Josh Freese, Finance Manager

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

MATERIAL WEAKNESS 2023-002 Policies and Procedures Auditor’s Recommendation: We recommend that the Foundation adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.327. Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings no later than December 31st, 2024. • As a First Year Single Auditee, the management team will ensure that specific policies are created to ensure a procurement process for goods and services expensed from federal funds is established and in alignment with UG (Uniform Guidance) standards for federal awards no later than December 31st, 2024. • As a First Year Single Auditee, the management team will have an independent audit firm review this policy to ensure they are in alignment and conformance with UG (Uniform Guidance) standards no later than December 31st, 2024.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County 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: 2023-002 Finding caption: The County did not have adequate controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of County contact person: Chuck Beyer, PO Box 97, 360-795-3301 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 Process Checklist has been completed and is in the Prosecuting Attorney’s office for review. We have written into the Process Checklist to maintain the documentation required when obtaining Professional Bids. Anticipated date to complete the corrective action: September 30, 2024

Auditor’s Recommendation: The Organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Corrective Action: Implement Policy A10 – “Grant Management Protocols.” Utilize Donor Database for managing subawards. Responsible for Corrective Action: Finance Team (Outsourced accounting firm, Operations Manager, Executive Director) Anticipated Completion Date: December 31 2024

Finding: 2023-009 All Programs Description of the Findings: During the review of the procurement compliance requirement related to major program, it was determined that the USWA did not have a document procurement policy in place until August 2023. Views of Responsible Official(s) and Planned Corrective Actions: While the Alliance did not have a standalone procurement policy in place until August 2023, it did have purchasing policies embedded in its Accounting and Finance Manual that covered purchases relative to our work at that time. No further corrective action is needed however policies are reviewed annually to ensure compliance under 2 CFR 200.516(a). Completion Date: August 2023 Responsible Official(s): ShaQuina Davis

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement new policies and procedures to ensure that all expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies for any new ARPA contracts. Most all of the 2023 expenditures were part of contracts that were already in place when the 2022 findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Sherri Crow, Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2024

Yakima Valley Conference of Governments has met with staff regarding procurement standards 2 CFR 200.318-327. We are implementing a purchase request form to be completed by management identifying the purchase requirement(s) to accurately document procurement methods and requirements. The purchase request form will be reviewed and approved by the Executive Director identifying the correct requirement for the purchase based on federal policy. Yakima Valley Conference of Governments has updated their internal policy for procurement to reflect the federal thresholds for purchases. Yakima Valley Conference of Governments has met with staff regarding suspension and debarment for purchases with federal funds. We are implementing a purchase request form to be completed by management requiring verification that the vendor is not suspended or debarred to be included in their purchase request. The purchase request form will be reviewed and approved by the Executive Director verifying documentation is included. Yakima Valley Conference of Governments finance specialist will pull suspension and debarment before the first payment to vendor. The documentation will be attached to the invoice voucher.

Yakima Valley Conference of Governments has met with staff regarding procurement standards 2 CFR 200.318-327. We are implementing a purchase request form to be completed by management identifying the purchase requirement(s) to accurately document procurement methods and requirements. The purchase request form will be reviewed and approved by the Executive Director identifying the correct requirement for the purchase based on federal policy. Yakima Valley Conference of Governments has updated their internal policy for procurement to reflect the federal thresholds for purchases. Yakima Valley Conference of Governments has met with staff regarding suspension and debarment for purchases with federal funds. We are implementing a purchase request form to be completed by management requiring verification that the vendor is not suspended or debarred to be included in their purchase request. The purchase request form will be reviewed and approved by the Executive Director verifying documentation is included. Yakima Valley Conference of Governments finance specialist will pull suspension and debarment before the first payment to vendor. The documentation will be attached to the invoice voucher.

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG, will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by March 31, 2025.

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Suspension and Debarment – Allen County did not have documentation that vendors’ suspension and debarment status were verified through either a) checking the Excluded Parties List System (EPLS), b) collecting a certification, or c) adding a clause or condition to the covered transaction agreement. Procurement – Allen County did not ensure purchases between $10,000 and $150,000 had received the adequate number of quotes or documented why an adequate number of quotes was not received. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2023-004 for Suspension and Debarment, the Chief of Staff to the Board of Commissioners will check the EPLS on SAM.gov every time a contract is placed before the Board of Commissioners for signature not containing the appropriate suspension and debarment language or a county department starts a project with a vendor using State and Local Fiscal Recovery Funds (SLFRF). If a vendor is not found in EPLS, a certification will be solicited from the vendor prior to contract signing or purchase of goods or services verifying that they have not been suspended or disbarred. A new verification must be sought for every contract or purchase. Documentation will be kept on file by the Controller to the Board of Commissioners who is responsible for reviewing claims submitted for payment utilizing SLFRF. To correct Finding 2023-004 for Procurement, the Chief of Staff to the Board of Commissioners will instruct departments who may be spending between $10,000-$150,000 of SLFRF that price or rate quotations must be obtained from an adequate number of qualified sources. When departments submit a claim to the Controller of the Board of Commissioners for payment, they must also provide a cover sheet outlining a) rationale for the method of procurement, b) copies of quotes received, and c) a justification for the selected vendor. This information will be reviewed and if everything is in order, the cover sheet will be uploaded, along with the accompanying invoices, in the Workflow payment system as part of the record. Anticipated Completion Date: This CAP will be completed by December 31, 2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Willapa Harbor January 1, 2023 through December 31, 2023 This schedule presents the corrective action planned by the Port for findings reported 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: 2023-001 Finding caption: The Port did not have adequate internal controls ensuring accurate and reliable reporting of its financial statements. Name, address, and telephone of Port's contact person: Jim Sayce 1725 Ocean Ave. Raymond, WA 98577 #360-942-3422 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 of Willapa Harbor plans to use the State Auditor's Resources to gain a better understanding of the required reporting's on the financial statement and get more familiar with the process. The Port of Willapa Harbor also plans to find another method to use when performing the cross walk of Accrual BARS to Cash BARS Numbers to ensure efficient and accurate reporting's. Anticipated date to complete the corrective action: May 2025

Corrective Action Plan for the Material Weakness identified as part of the Single Audit Reports For the Year Ended December 31, 2023 Finding Number 2023-001 Contact Person(s): Patrick Evans, CEO Material Weakness: The Organization received and utilized the federal award to pay for general contractor services for a construction project that was ongoing at the time of the award. The Organization had entered the procurement of general contractor service prior to receiving the federal award and in accordance with its existing procurement policy,which included a competitive procurement process with a price analysis. However, there was not a procurement policy in place that specifically covered the criteria required under the Uniform Guidance. As a result, the Organization did not have a procurement policy and process in place that resulted in compliance with the Uniform Guidance including the maintenance of records to detail the history of the procurement in accordance with 2 CFR 200.318(i). Corrective action planned: ERC will update the existing procurement policy to be in accordance with the Uniform Guidance. Once the policy is completed, procedures will be developed to ensure compliance with the policy and training provided for personnel responsible for federal procurements. Anticipated completion date: 3/31/2025

Significant Deficiency and Noncompliance – Procurement Documentation Statement of Condition/Criteria: Delta County is not following its procurement policy and is therefore not meeting the requirements of 2 CFR section 200.318 to use documented procurement procedures. The County does not have controls in place to ensure that written records are maintained sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The County did not maintain documentation to sufficiently support a written price analysis on one procurement tested. The County was unable to provide proposals from nonwinning bidders and/or a price analysis when only one bid was received on two contracts tested. The County does not have formal procedures or controls in place to ensure written documentation of a cost analysis or a contract file are maintained. Planned Corrective Action: County management has started to develop controls to ensure the procurement policy is followed and will continue to develop controls to ensure that complete contract files with a price analysis are maintained. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2025