Corrective Action Plans

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) A formal procurement policy will be developed and implemented at the agency’s earliest convenience, but no later than July 31, 2024. 2) Provide training to procurement personnel on the new policy and procedures. Name of the contact person responsible for corrective action: Talana Lay, Board Treasurer Planned completion date for corrective action plan: July 31, 2024 If the U.S. Environmental Protection Agency has questions regarding this plan, please call Talana Lay at 509-322-5973.

Finding Number: 2023-002 Condition: The Society did not have documentation to support that two covered transactions were checked for potential suspension or debarment before entering into the transaction. There was one covered transaction where the Society did not have documentation to support the procurement process followed or that more than one vendor was reviewed for pricing before selecting the vendor chosen. Planned Corrective Action: Staff turnover in early 2023 resulted in limited capacity for dedicated staff to check for potential suspension or debarment before adding vendors to the system. We have dedicated staff who will be managing this process going forward. The Society has written procurement policies and procedures. Key leadership stakeholders have been apprised of our policies and procedures. The Society will be implementing a training series for government funded procurement stakeholders within the Society to ensure compliance. Contact person responsible for corrective action: Dharshni Sabapathy, Senior Director of Accounting Anticipated Completion Date: April 25, 2024

Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. 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. Ac􀆟on Taken: BGCDC has already established a Uniform Guidance worthy procurement policy and is currently working on an update to the Conflict-of-Interest policy. These will go to our Finance Committee and Board soon for full approval as well as implementation. Leadership has been informed of this change and is already starting on the implementation as far as seeking out bids, documenting rationale, and making informed decisions. The contact person responsible for the corrective action is Wendi Speed, CFO. The anticipated completion date is June 30, 2025.

Sufficient Documentation for Noncompetitive Proposals for Pacific Fisheries Data Program, 11.437 Recommendation: CLA recommends increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will modify its subcontractor request form and PO form to require competitive supporting documents or non-competitive justification documents to be attached with the subcontractor request or PO form. Contract Specialist and Purchasing Specialist will review request package to ensure all required paperwork completed properly before moving forward with the process. In the pipe line, Requisition Module in Navision Software will be designed to put a hard stop if a purchase order of $10,000 or greater is missing supporting document for competitive/non-competitive procurements. Name(s) of the contact person(s) responsible for corrective action: Kathy Ameral and Michael Arredondo. Planned completion date for corrective action plan: October 15, 2023

Federal Agency Name: U.S. Department of Transportation; U.S. Treasury Department; Assistance Listing Number(s): 21.027; 20.507; Program Name(s): Federal Transit Cluster - FTA 5307 CARES Act 2020; COVID-19 Coronavirus State and Local Fiscal Recovery Funds Material Weakness in Internal Control Over Compliance – Compliance Requirement – Procurement, Suspension, and Debarment Finding Summary: The City’s purchasing policy is missing elements required by Uniform Guidance, the City did not verify vendors were not suspended or debarred before entering into contracts with vendors, and elements required to be included in contracts with vendors paid using federal monies were missing from contracts. Corrective Action Planned: The City concurs with the auditors’ findings. The City is working to develop an updated purchasing policy, improve processes, and continue training staff around purchasing and contracting to ensure Uniform Guidance requirements are met, and specifically, that vendor contracts include elements required when using federal monies, and the vendors are checked against the suspended and debarred listing. Responsible Individual(s): Mark Hagedorn, Finance Manager/Treasurer; Brooks Slyter, Assistant Finance Manager Anticipated Completion Date: March 2025

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