Corrective Action Plans

Description of Finding: Internal Control over Compliance with Suspension and Debarment Requirement Statement of Concurrence or Nonconcurrence: There is no disagreement with this finding. Corrective Action: Management will implement new procedures to verify suspension and debarment status of vendors and contractors for all covered transactions over $25,000. Projected Completion Date: June 30, 2024

Finding 2023-001: Internal Control Over Financial Reporting Corrective action: Because of its size, the City does not feel it is cost effective to hire an employee(s) with the experience and technical training to prepare its financial statements. The City is, however, willing to assist with the preparation and will continue to work to gain experience in this area. Responsible Person: Blyann Johnson Anticipated Completion Date: Ongoing Finding 2023-002: Internal Control Environment Corrective action: The City is aware of our lack of controls over accounts payable/disbursements, payroll, property taxes, utility billing and collection and period close. Because of our size, we do not feel it is cost effective to hire the number of employees needed to cure these internal control deficiencies. Responsible Person: Blyann Johnson Anticipated Completion Date: Ongoing Finding 2023-003: Significant Deficiency - Internal Control Over Procurement, Suspension and Debarment Corrective action: Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Responsible Person: Blyann Johnson Anticipated Completion Date: 12/31/2024

The School District will follow proper procurement procedures related to food purchases.

Finding Number: 2023-005 Condition: Two of forty contracts was entered into with a contractor without verification that the entity was not debarred, suspended, or otherwise excluded. As well as two of forty contracts that were tested did not have documentation to support that either the small purchase procedures were followed or the rationale for a noncompetitive solicitation was documented. Planned Corrective Action: Management will ensure that all contracts include verification that an entity is not debarred, suspended, or otherwise excluded and maintain documentation of this review in the contract file. While our current internal controls already support this practice, we acknowledge that there were instances in which this was unintentionally missed. We are re-educating procurement staff regarding the necessity of these verifications. Additionally of note, is that the contracts in question related to emergency professional services in support of MTA's response to the global pandemic. Due to the emergent situation, the ideal processes were not followed. We acknowledge that internal controls must be followed for all contracts, regardless of urgency. Furthermore, the contract should have been reevaluated when the Public Health Emergency ended, and the processes used should have been fully documented. We will endeavor to have full documentation in the future. Contact person responsible for corrective action: Colette Champine, CFO/Corwin Matthews, COO Procurement & Capital Projects Anticipated Completion Date: Already completed

The Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy. Response and Planned Corrective Action: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures. Planned Corrective Action: • When using federal funds, the Business Manager/Asst. Business Manager will ensure that cooperative purchasing programs or noncompetitive purchasing arrangements comply with the UGG procurement policy. • The Business Manager/Asst. Business Manager will document the process and how it complied with the procurement standards and keep such documentation with Federal Award budget/procurement documents.

April 15, 2024 Donovans CPA www.cpadonovan.com RE: Findings 2023-001 Procurement Assistance Listing Number 84.282A Dear Sirs; Lawrence County Independent Schools has implemented the following Corrective Action Plan in response to the finding of the Single Audit for fiscal years ending 2023. Corrective Action Plan 1. The LCIS Procurement Policy has been updated by the Director of Schools, Joanne Symcox, under the non-Federal entity (Per 2 CFR 200.318) to conform to procurement standards identified in 200.317 through 200.327. 2. The updated policy will be presented at the March 21, 2024 Board Meeting for review and approval. 3. The corrective action plan was implemented beginning Mar 13, 2024. 4. The Director of Schools, Joanne Symcox is responsible for plan implementation and adherence. Sincerely, Joanne Symcox

Finding Number 2023-001 Contact Person(s): Rick Johnson, VP of Finance and Administration Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Corrective action planned: The Seattle Aquarium will provide training for employees involved in procurement exceeding the simplified acquisition threshold to ensure they are aware of the various procurement methods and requirements. Review of the procurement process by the Finance Department will be required for such planned purchases. Anticipated completion date: June 30, 2024

GRANT REPORTING Finding: The Audit Certification Memo for fiscal year 2022 (due June 30, 2023) and the Section 3 Summary Report (due July 31, 2023) were not filed with the DOC. Further the Contract and Subcontract Activity report (due on April 15, 2023) was not filed timely (filed September 7, 2023). With regards to the reimbursement request, the initial reporting was rejected due to noncompliance with procurement provision in the grant agreement. As a result, the DOC denied $74,813 of the City’s request as ineligible expenditures. Management’s Response: The city has filled a position focused mainly on projects & grants reporting. The employee will verify all grant requirements are fulfilled on time and according to the grant contract. Processes are being put in place that will include conversations with the project manager which will ensure they are notified of the necessary steps to fulfill the requirements, as well as final finance review to ensure compliance. Implementation Timeline: April 1, 2024 Responsible Party: Patrisha Draycott, Chief Financial Officer

Contact Person Neil Breidenbach Planned Corrective Action The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Planned Completion Date December 31, 2024.

2023-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2024 Corrective Action: Management agrees with the findings and recommendations set forth within. During the first quarter of fiscal year 2023, prior to the 2022-001 finding, noncompetitive procurements completed followed the prior procurement policy that did not align with Uniform Guidance as relates to noncompetitive procurement justifications. The Corporation has since completed its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. Training on the Uniform Guidance procurement requirements was developed and required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. Moreover, during the first quarter of the fiscal year 2023, NeighborWorks implemented a new contracts management system that will be used to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. During fiscal year 2024, management has continued its response to the recommendations by engaging with technical experts to enhance the contracts management system and strengthen internal controls. Additional training is being developed on the enhanced system and processes to ensure continued compliance with Uniform Guidance as relates to noncompetitive procurements.

Procurement and Suspension and Debarment Recommendation: We recommend that the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will implement additional policies and procedures in relation to ensuring vendors used are not suspended and debarred. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: April 2024

Management will create a reviewed and current procurement policy that covers all major areas of the Uniform Guidance requirements for procurement, suspension & debarment and ensures procedures are clear, accessible, and easily understandable by all sta􀆯 involved in procurement activities.

Condition/Context: For this program for our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor. Corrective Action Planned: • Management will update existing procurement policies in accordance with the Uniform Guidance and implement a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. Anticipated Completion Date: April 15, 2024 Name of Contact Person Responsible for the Plan: Elizabeth Sergel

2023-002 U.S. Department of Transportation, National Infrastructure Investments: Better Utilizing Investments to Leverage Development (BUILD) Grant Assistance Listing Number 20.933; Procurement Material Weakness in Internal Control over Compliance Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. 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. The Port Authority’s formally documented policy pre-dates Uniform Guidance and does not include many of the necessary procurement provisions. Corrective Action Plan: An updated Procurement Policy is being drafted to meet the standards set forth in 2 CFR 200.317 to 220.237, then reviewed and approved by our Board at the next appointed board Meeting. Expected Completion Date: March 2024 Responsible Individuals: Kimbra Scott

Corrective Action Planned: The Board will ensure compliance with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Anticipated Completion Date: The completion date is March 15, 2024 Contact Person(s): Cindy W. Parker; Chief School Financial Officer; cparker@blountboe.net

Views of Responsible Officials: IW will initiate a thorough review and revision of our procurement policy to ensure full compliance with the Uniform Guidance. This revision process includes adding documentation of the procurement process. In addition, it will address how we incorporate specific procedures for conducting and documenting checks against the System for Award Management (SAM) to verify the status of vendors prior to engaging in covered transactions. We will implement a standardized documentation process to maintain evidence of SAM checks within our vendor files. This includes a detailed log of each check performed, the date, the name of the entity checked, and the outcome. These records will be retained as part of our procurement files for audit and review purposes.

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so its clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2024.

Finding 2023-002: Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement, Suspension, and Debarment Standards. Name of Contact Person: Angela J. Vanderpool, Executive Director. Corrective Action: The finance department will create and implement a checklist that reflects the finance procurement policy to ensure the policy is followed before a procurement is awarded to a vendor. Proposed Completion Date: June 2024

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30 2023 Name of contact person: Kristen Galbraith, GPC Corrective Action: The Grants Department will develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No. Direct and AM-23-0287 Name of contact person: Kelly Strecker Corrective Action: The City commits to ensuring that a procurement policy be put in place that will allow it to comply with procurement standards outlined in the Uniform Guidance. Proposed Completion Date: December 1, 2024

Initial Fiscal Year Finding Occurred: 2023 Federal Agency Name: U.S. Dept of Housing and Urban Development Program Name: Continuum of Care CFDA #: 14.267 Finding Summary: Significant Deficiency over Internal Controls over Compliance. Procurement, Suspension, and Debarment During testing, it was identified that the Organization was not following its procurement policy. Responsible Individual: Theresa Perkins, Chief Financial Officer Corrective Action Plan: The NAC leadership team is responsible for the following and will report on the following for FYE 2024: Provide a final Procurement Plan that has been reviewed and updated and approved by the Board. Anticipated Completion Date: June 30, 2024

2023-004 - Procurement, Suspension, and Debarment – Internal Control over Procurement and Verification Against the System for Award Management (“SAM”) (Significant Deficiency) Condition: Community Development Block Grants-Entitlement Grants Cluster Based on the City’s formal purchasing policy, purchase orders are required to initiate purchases from procured vendors for transactions above $5,000. During our audit, we noted that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. Coronavirus State and Local Fiscal Recovery Funds We determined that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. During our audit, we also noted that there was no supporting document to indicate that the City verified the vendor against the SAM to ensure the vendor was not suspended or debarred from federally-funded programs before the contract was entered into. Management concurs. Corrective Actions: The City has an existing purchasing policy and procedures that require documentation for all purchases. Finance department has sent to all department heads reminder and the importance of compliance with the policy and procedures. The reminder also emphasizes the necessity of preparing a purchase order before procuring products or services from a vendor. There may be certain circumstances preventing the preparation of a purchase order prior to procurement, such as the nature of the services or the urgency of acquiring materials and supplies, departments may proceed with the procurement as long as the services or purchases are within adopted budget. City Council approved the Federal Award Management Policy & Procedures on agenda item #4 on December 6, 2023. Finance staff has also updated the requisition form to include a verification of SAM.gov clearance, requiring any backup indicating the vendors status if it is federally funded. City staff has been diligently verifying the suspension or debarment for all federally funded expenditures. Implemented Name of Responsible Person: Robert A. López, Chief of Police Manuel Carrillo Jr., Director of Recreation & Community Services Ron Garcia, Director of Community Development Sam Gutierrez, Director of Public Works Rose Tam, Director of Finance Albert Trinh, Accounting Manager Projected Implementation Date: All actions needed have been Immediately implemented.

2023-002 Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: It is recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will review procurement and purchasing policies and implement polices and controls to ensure that District policies and controls comply with Uniform Guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Brenda Arnett Planned completion date for corrective action plan: June 30, 2024

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-008 The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Corrective Action Plan: The College obtained multiple quotes for a Wi-Fi refresh project. The Chief Information Officer, under the guidance of the Vice President of Finance and Administration, analyzed these quotes and determined that one of them most closely met the needs of the College. This quote was submitted to Laurens County as part of the ARP Infrastructure Application, prepared by the College’s Corporate & Foundation Relations Officer. After Laurens County granted the funding for the Wi-Fi project to the College, the College moved forward with the vendor and scope of work laid out in the quote. However, the College does recognize that it did not adhere to all aspects of the Federal Procurement Policy. The Vice President of Finance and Administration, along with the Controller, will both implement a procurement policy for any purchases made with Federal funds that satisfies the requirements laid out in the Federal Procurement Policy and also educate any faculty/staff involved in purchasing products/services involving Federal funds.

Finding – Internal control deficiencies over procurement requirements Name of contact person: Lane Millar, Finance Director Corrective action: The City will ensure that employees receive comprehensive training on procurement requirements as a prerequisite before undertaking those responsibilities. Proposed completion date: March 1, 2024