Corrective Action Plans

Brightside Up, Inc will review the procurement policy and document considerations for any vendors that meet the thresholds and verify the vendors' compliance through sam.gov. Contact person Keely Weise, CFO, 518-426-7181, kweise@brightsideup.org. The anticipated date for resolving the audit finding is December 31, 2024. Brightside Up, Inc will research through sam.gov, every vendor that is paid with Federal funds.

FINDING 2023-004 Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that proper procurement procedures for small purchases were followed. Due to the lack of oversight or implemented controls small purchases paid to eight vendors totaling $180,015 were made without obtaining price or rate quotes. The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. One covered transaction that equaled or exceeded $25,000 was identified and selected for testing. Transactions to the vendor totaled $81,295; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The corporation will have adequate internal control in place and the corporation will develop a procedure to ensure rate or priced quotes are obtained for small purchases and ensure contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: April 2024

Management agrees with the finding. Management has drafted a procurement policy, and will enact and enforce this policy by the end of 2024. This policy will be reviewed annually to ensure that any changes in laws and regulation are reflected in internal procedures.

9/11 Day takes great care in evaluating and selecting vendors that support its programs, both in terms of the vendors’ abilities to deliver high quality services and their ability to do so cost effectively. For all major expenses we require advance cost estimates and competitively evaluate them. To comply fully with 2 CFR 200 9/11 Day is now in the process of adopting a formal procurement policy. It is the intention of 9/11 Day to finalize and adopt that process by 12/31/2024, and will apply it on a go forward basis to all future federally-supported procurement activities.

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization will continue to abide by its procurement policy and will check its vendors against the exclusion list on the System for Award Management website. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date October 31, 2024

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: Action steps Who At least quarterly program level review of budget vs. actuals to discuss trends, variances, potential errors in coding of transaction Finance Team and Executive Directors At least quarterly review of admin costs, to review for trends against budget and errors in classification of transactions Finance Team and Executive Directors Adjust cadence /deadlines for balance sheet reconciliations and incorporate Finance Director level review. Ensure adjustments are made in a timely manner. Finance Team Email weekly cash deposit report for Executive Directors and Finance Director to review for proper classification in the general ledger Finance Team and Executive Directors Streamline key processes which will allow finance team the time and flexibility to analyze and strategize and get ahead of firedrills; this will allow them to understand the story that the numbers are telling. Finance Team Continue to document procedures. This will ensure proper backup when team members are out due to vacation or illness. Comprehensive, documented procedures are the teams bench strength. Finance Team Ensure all transaction in the general ledger have proper backup to ensure understanding of underlying transaction Finance Team Anticipated Completion Date: End of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard and Tara Moss, Co-Executive Directors

Actions Taken: Management has updated the Conflict of Interest policy to include all the elements required by 2 CFR § 200.318. The updated policy includes procedures for evaluation and management of conflicts, mitigation strategies, enforcement mechanisms, training and communication provision, and procedures for regular review and update.  Implementation Date: September 30, 2024  Person Responsible: Juan Carlos Consuegra, President

Recommendation: The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation: There is no disagreement with the audit finding. Action taken in response to finding: The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies. Name(s) of the contact person(s) responsible for corrective action: Norman Barlow, City Manager Amanda Marlow, Assistant City Manager Planned completion date for corrective action plan: Procurement training and monitoring, ongoing Suspension and debarment training and monitoring, ongoing

Recommendation: The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation: There is no disagreement with the audit finding. Action taken in response to finding: The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies. Name(s) of the contact person(s) responsible for corrective action: Norman Barlow, City Manager Amanda Marlow, Assistant City Manager Planned completion date for corrective action plan: Procurement training and monitoring, ongoing Suspension and debarment training and monitoring, ongoing

Recommendation: The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation: There is no disagreement with the audit finding. Action taken in response to finding: The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies. Name(s) of the contact person(s) responsible for corrective action: Norman Barlow, City Manager Amanda Marlow, Assistant City Manager Planned completion date for corrective action plan: Procurement training and monitoring, ongoing Suspension and debarment training and monitoring, ongoing

Incorporate a Federal Procurement Policy (Res # 24-11)

Finding Number 2023-002 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: ULMS’s policy on procurement outlines the process and documentation required to select vendors for contracts over the micro-purchase threshold. The policy was followed, but documentation could not be retrieved as it was not submitted to accounting and some of the decision makers of the contract are no longer with ULMS. Management recognized this issue and created a procurement form that streamlines the selection, justification and documentation of the process in March 2024 which was before the organization was informed of this finding. Additionally, management transitioned the form online in August 2024 and a copy of the completed form is automatically sent to ULMS’s procurement email. Management also provided procurement training to all employees involved in the procurement process. Anticipated Completion Date: Date completed 3/19/2024

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

Management Comments and Corrective Action: Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related to those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization hired new procurement leadership and invested in Full Time Employees (FTEs) to develop a robust procurement department. Due to this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provide tools for selecting the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2025. Person Responsible for Corrective Action: Steven Beckman, CFO

Coronavirus State and Local Fiscal Recovery Fund – Assistance Listing No. 21.027 Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Any new vendors selected for the SLFRF program will be reviewed for suspension or debarment by the Auditor’s office in SAM.gov. Auditor’s office has discussed the process of procurement documentation of all SLFRF program vendors with administrative personnel. Name(s) of the contact person(s) responsible for corrective action: Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: November 30, 2024

Mexico Water District agrees with this finding. The Conflict-of-Interest Policy was voted on and adopted on September 9, 2024, and each Trustee signed an acceptance form.

Reference: 2023-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus Frederickson, Mayor; Patrick Reagan, City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2025

Contact Person – Scott Froemming Corrective Action Plan – Meeker Cooperative will create and implement a procurement policy that complies with state and local regulations as well as 2 CFR Part 200.317 through 200.327. Completion Date – October 31, 2024

Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable.

Views of Responsible Officials and Action Taken: We agree with the finding and recommendation and have implemented a verification step in our vendor approval and onboarding process which requires all vendors to be run through the SAM website and debarment search. We also require an annual verification to be performed for all vendors.

Contact Person Responsible for Corrective Acton Plan: Debbie Nelson County Auditor. Condition We noted during testing procurement, suspension, and debarment that the County doesn't have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 2 of our 2 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2024

We value your guidance and are committed to enhancing our compliance with the Uniform Guidance. In response, we will: 1. Documentation Procedures: We will implement procedures to properly document procurement activities. This will help us maintain consistency and ensure compliance with the Uniform Guidance. 2. Monitoring and Accountability: Additionally, we will establish a system to regularly monitor our compliance with these policies and procedures. This will enable us to quickly address any issues that may arise. The Finance Department will be responsible for implementing these changes and will have everything ready before the end of 2024. We are dedicated to making these improvements and truly value your support as we work through this process. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024

We understand how crucial it is to have strong policies and procedures in place. Here’s how we plan to move forward: 1. Review of Existing Policies and Procedures: We’re currently taking a close look at our existing policies and procedures to ensure they align with the Uniform Guidance. This will help us identify any gaps and make necessary updates so that we’re fully compliant. 2. Development of New Policies: Alongside this review, we will create clear and comprehensive written policies in key areas, such as: • Cash Management: Setting up procedures that comply with 2 CFR 200.305 to ensure timely payments. eCFR :: 2 CFR 200.305 -- Federal payment. • Allowability of Costs: Crafting guidelines that follow Subpart E—Cost Principles, so we can confidently determine which expenses are allowable. https://www.ecfr.gov/current/title-48/chapter-7/subchapter-E/part-731/subpart-731.7/section-731.770. • Conflict of Interest: Establishing standards of conduct that address potential conflicts and promote transparency. • Equipment and Real Property Management: Developing policies for managing equipment acquired under federal awards in line with 2 CFR 200.313(b). eCFR :: 2 CFR 200.313 -- Equipment. • Procurement Procedures: Creating clear procurement guidelines that align with 2 CFR 200.318 through 200.326 to ensure fairness and oversight. eCFR :: 2 CFR 200.318 -- General procurement standards. 3. Training and Communication: The Finance Department will be responsible for training all staff involved in managing federal awards. Training sessions will ensure that everyone understands the requirements and their roles in maintaining compliance. This training will be completed by December 31, 2024. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024

Management will develop, adopt and implement a procurement policy for federal purchases that aligns with the requirement of the 2 CFR 200 Uniform Guidance. This process will include steps within the interview and application process to ensure contractors and subrecipients are eligible (not suspended, debarred, or otherwise excluded) to enter into an agreement, contract, or subaward with the City. The process will also include steps to ensure all necessary language, such as the Buy America Build America Provisions are included in the final contracts.

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). 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.