Corrective Action Plans

Management agrees with the auditors’ comments, and the March of Dimes (MOD) has taken the following steps to strengthen the related internal controls. Due to transitions in personnel and decentralized filing systems the supporting documentation for the competitive bid process/sole source justification related to two procurement transactions and the suspension and debarment check related to one procurement item were not maintained. To address the document retention concerns MOD stood up Asana, a grant tracking system, during 2023 for project management and implemented a 7-step checklist for grant funded procurement that includes a centralized housing location for documentation. Asana and the complementary process were fully implemented in October 2023 with compliance overseen by the Office of Sponsored Projects (OSP) with regular support, guidance, and periodic validation from the Finance Office through weekly meetings with the Director of Grants Accounting. To further expand MOD staff knowledge and expertise regarding federal grant management, by the end of October 2023, all key finance and program personnel using grant funds for salary or other expenses and/or fulfilling grant goals and deliverables received a certificate for completing the Center for Disease Control Foundation’s Federal Grants Management training. By December 2024, MOD will host a virtual Federal Grant Management staff training for all key finance and program personnel that use federal grant funds. This training will include the recent revisions to 2 CFR 200. Beginning in January 2024, MOD also implemented grant on-boarding for staff using grant funds as new grant awards are received.

Contact Person – Lisa Prachar, VP/CFO Corrective Action Plan – East Central Energy and Subsidiaries is currently developing a written procurement plan that adheres to minimum standards. Completion Date – December 31, 2024

Corrective Action Planned: The Organization will draft, adopt, and implement a procurement policy. Anticipated Completion Date: September 17, 2024 Responsible Parties: Board of Directors

Management will strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained. Christopher Caulfield, Executive Director of Financial Operations, will effectuate the corrective action plan, which is anticipated to be completed by December 31, 2024. caulfieldc@sjhmc.org 973-754-2016

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: The City did not obtain price or rate quotes for the one vendor tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the City did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. A population of 9 covered transactions for goods or services were paid from Coronavirus State and Local Fiscal Recovery Fund funds during the audit period. A sample of 3 transactions were selected for testing. Of the 3 transactions tested, 1 vendor was not verified to not suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Craig Wright - Controller Contact Phone Number and Email Address: 765-747-4828 cwright@muncie.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

Title of result and comment:: Frankton FINDING 2023‐003 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: All contract we make will start going through, Checking SAM Exclusions; or Collecting a certification from that person; or Adding a clause or condition to the covered transaction with that person". We will also add a clause that any Federal Government Grant will buy America Preference Material. Anticipated Completion Date: Year: 2024 Month: 5 Day: 14 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 32 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

FINDING 2023-05 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: No procurement policy is in place and vendors were not confirmed to not be suspended or debarred. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Additionally, a procurement policy will be put into place. Anticipated Completion Date: August 30, 2024

Contact Person - Pattie Solberg, Auditor; Corrective Action Plan - The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date - December 1, 2024.

Management Response The Garden followed the procurement requirements of the OMB and Uniform Guidance but did not codify its policy in writing. Corrective Action Plan: The procurement policy is now written. Education of and reverification of the federal procurement processes will be provided to all Principal Investigators and others involved in Grant Management by August 31, 2024. Contact person(s) responsible for the corrective action: Diane Wondolowski, Director of Finance, dwondolowski@sbbotanicgarden.org Anticipated Completion Date: The policy is in writing. Education will be complete by August 31, 2024.

FINDING 2023-003 Finding Subject: COVID 19 Procurement Suspension and Debarment Summary of Finding: We did not have a policy for procurement and debarment for federal funds Contact Person Responsible for Corrective Action: Amy Roberts Contact Phone Number and Email Address: ARoberts@dalevilleindiana.org 765-378-6288 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will create a policy for future federal fund expenditures Anticipated Completion Date: March 1, 2025

Corrective action plan: Management believes that the procurement process has improved during the last year. The threshold for obtaining quotes was raised to $10,000 from $2,000, so there are significantly fewer transactions to monitor for compliance. The program managers are practicing more price comparison and obtaining quotes for purchases over $10,000, but not in every instance. The Finance Manager and the Accounts Payable Clerk will continue to monitor the documents submitted with purchase requests. Finance will not issue a check for payment to a vendor over $10,000, unless an adequate number of quotes and/or a sole source justification for the purchase has been submitted to document compliance with procurement standards For purchase requests over $10,000, the Finance Manager will perform a search of the database records on Sam.gov to determine if a vendor has been suspended or debarred. The Finance Manager will note on the purchase request the status of the organization according to Sam.gov and the date of the search. For those entities that are determined to be suspended or debarred, the purchase will not be approved. Personnel responsible for corrective action: Lisa Donham (Finance Manager), Deidre Moyer (Accounts Payable), and Program Managers Estimated corrective action completion date: December 31, 2024

Moonshot Missions agrees with the findings and auditor recommendations. See corrective action plan under finding 2023-001. Moonshot will ensure purchasers document the suspension and debarment check through the SAM database prior to entering into any procurement agreements. Moonshot Missions will ensure all subrecipients and contractors are in compliance with 2 CFR parts 180 and 1532 when using EPA funds.

The Organization agrees with the recommendation. The procurement policy was updated in August 2024 with all the elements required by the UG.

Auditor's Recommendation: This circumstance is not unusal in an entity of your size which has never been required to have a Single Audit. We recommend that the Village Board implement written policies and procedures for procuring goods and services and standards of conduct to follow when procuring those goods and services. Action Taken: The Village Board was unaware that written policies and procedures for procuring goods and services was required under the Uniform Guidance. We are a small municipality and have never been required to have written polices and procedures for purchasing goods or services. Anticpated Completion Date: We will work on drafting written policies and procedures for procuring goods and services and standards of conduct for employees to follow when procuring those goods and services so we are in compliance with the Uniform Guidance.

FINDING 2023-003 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster -Procurement Summary of Finding: The Town did not obtain price or rate quotes for the two vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the Town did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Contact Person Responsible for Corrective Action: Sherry Ervin Contact Phone Number and Email Address: 765-478-3522 cctownclerk@comcast.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Town will document in the minutes when there is only one (1) vendor available for the purchase of equipment Anticipated Completion Date: By year end 12/31/2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Skamania 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: 2023-001 Finding caption: The County did not have adequate controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of County contact person: Robert Waymire, Auditor P.O. Box 790 Stevenson, WA 98648 (509) 427-3731 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 County has already begun putting together an informal bidding policy and procedure document that will include a federal procurement section. Once the policy is in place, it will be distributed to all departments for their use. Anticipated date to complete the corrective action: December 31, 2024

Condition: Controls in place were not adequate to ensure support for suspension and debarment check was retained. Planned Corrective Action: The Authority will work to establish a control that will ensure suspension and debarment checks are retained. Contact person responsible for corrective action: Shedreka Miller Anticipated Completion Date: 12/31/2024

2023-002 U.S. Department of Environment Protection – Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures – Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: The water systems improvements federally funded project is the Authority’s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority has been working over the past year to draft and develop these policies and procedures as they relate to federal programs, and to get them documented in writing. The Authority is currently working with their attorney to have the written polices established and plan to have this completed within the next fiscal year. Once the required policies are written, the Board of the Authority will review the policies, revise as appropriate, and adopt the policies for the Authority to comply with the federal funding requirements.

Finding 2023-001 – Internal control deficiency and noncompliance over Procurement 1) Communication & Awareness: • Debrief by Director, Research and Sponsored Awards with the Community Health Department Senior Leaders and Program Managers regarding the audit finding; including procurement requirements, the nature of the deficiency and failure points. This occurred on 8/27/2024. • Meeting between Director, Research and Sponsored Awards, PHS Communications and Brand Management leadership and VP of Community Health to communicate procurement requirements and clarify responsibilities for communication of applicability of Federal procurement requirements to specific projects for which advertising services are requested. Initial Meeting occurred 8/28/2024. 2) Training & Education: • Targeted Training with the Community Health department (primary recipient of on-going Federal funding) on Federal procurement requirements. This training will be provided by the Research and Sponsored Awards staff and will be extended to any additional departments new to Federal funding. • Enhancement of existing required annual enterprise-wide leadership training that includes a section on grant funding with increased emphasis on procurement. Research and Sponsored Awards department is responsible for content. • Development of materials for new hires or others new to grant funding who are responsible for federally funded projects (collaboration between Research and Sponsored Awards department and Community Health department) 3) Policies & Procedures: • Written Procedures & Toolkits: Development of written procedures for contracting, exclusion checks and general procurement of goods or services to include checklists / toolkits to facilitate actions required for compliance with Federal procurement rules. • Update to existing policy “Federally funded Grants or Contracts – Procurement / Purchase of Supplies, Services and Other Property” to clarify the responsibilities for communication of applicability of Federal procurement requirements when a department receiving Federal funding procures goods or services through other PHS departments. 4) Collaboration with PHS Marketing department to ensure pathways exist for competitive bids, when necessary, including documentation of processes related to procurements under Federal funding. The first meeting was held 9/12/2024. 5) The Director, Research and Sponsored Awards and Community Health Department will review the items identified as questioned costs to identify if any improper payments were made to PHS. Contact Person: Lori Galves, Director, Research and Sponsored Awards Anticipated Completion Date: December 31, 2024

The District agrees with the recommendation from the State Auditors Office to strengthen internal controls to ensure the procurement policy is followed. The District will update its current procurement policy to include emergency procurement procedures, including the requirement for documentation of rationale if waiving competition during an emergency. The revised policy will conform with Uniform Guidance (2 CFR 200.318-327) and follows state/federal laws. The District will train staff to ensure the policy is followed for future goods and services.

Corrective action the auditee plans to take in response to the finding: Procurement The City of Grandview will update our procurement policies to comply with federal procurement requirements. The procurement policy update will include other required procedures for procuring transactions, such as contracting with small and minority business owners, women’s business enterprise and labor surplus area firms, domestic preferences, recovered materials, contract cost or price analysis and more. Going forward, the City will establish internal administrative controls to ensure that city staff receive the proper training and are aware of all procurement policies and guidelines. Suspension and Debarment The City of Grandview will establish internal controls on contract proposals exceeding $25,000, must be reviewed to ensure that contractors are not suspended or debarred. The City will verify this by adding a clause or condition into the contract that states the contractor is not suspended or debarred. The City will verify this before entering into a contract or purchasing goods and services, and it will maintain documentation demonstrating compliance with federal requirements.

Views of Responsible Officials: The Center will update its procurement policies and ensure staff are trained on all procedures and requires documentation. Name and Title of Responsible Official(s): Vibha Bhatia, Vice President of Finance and Operations Anticipated Completion Date: September 30, 2024

Texas Biomed has detailed procurement policies in place that outline requirements relative to expenditures on federal awards. Historically, training of new employees in Purchasing and employees in other departments with purchasing-related responsibilities was provided periodically. Turnover in 2023 affecting the Purchasing department led to a failure to ensure adequate training was provided such that compliance responsibilities were clearly understood. With the implementation of a new P2P system in Q3 2024, training has been updated for the new system and will incorporate reminders of compliance requirements for federal awards. Separate trainings are planned for September 2024 for Purchasing staff and for staff in other departments involved in the purchasing process. Training will include requirements to obtain and document multiple quotes for purchases over $10,000 and to document sole source justification when there are no other viable suppliers for a purchase. Purchasing staff will review requisitions to ensure the appropriate documentation is saved with the Purchase Order in the purchasing system. Any new employees or temporary workers in the Purchasing department will be trained on the requirements before they are allowed to begin processing purchase requisitions. Responsible Parties: Eva Zepeda, Director, Finance; Patricia Thompson, Assistant Director, Materials Management Completion Date: September 30, 2024

FINDING 2023-002 Finding Subject: Water and Wastewater Disposal Systems for Rural Communities – Procurement Summary of Finding: One vendor was not procured according to the simplified acquisition threshold. Contact Person Responsible for Corrective Action: Tammy Selby Contact Phone Number and Email Address: 812-354-8511 tselby@petersburg.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, we will bid out all professional services. We will follow our same policies for bidding out to other vendors. Anticipated Completion Date: December 31, 2024

Finding 2023-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Findings: The County did not have a Board approved procurement policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. The County had five vendors that qualified for testing under small purchase procurement requirements (vendors paid $10,000-$150,000). Of the two chosen for testing, one was awarded a contract without the County obtaining quotes. The contract awarded was $31,000 for engineering services related to drain construction. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process was not clear to the Auditor’s Office or the departments submitting the claims for payment. We are more aware of the correct process and procedures that need to take place and will add those procedures to our Internal Control policy to ensure that the vendor is not suspended or debarred. Anticipated Completion Date: October 2024