Corrective Action Plans

Finding 2023-001: Procurement United States Department of Agriculture – Child Nutrition Cluster United States Department of Agriculture – Child and Adult Care Food Program Criteria: The non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rational 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)). The non-federal entity must also establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) (2 CFR section 200.303(a)). Condition: Records detailing which vendors were contacted, when they were contacted, and support for the rationale in choosing the vendor, is not documented. Questioned Costs: None Cause: Management did not maintain a detailed history of procurement and did not document a review process. Effect: There is no reasonable assurance that the Organization managed the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award Recommendation: Purchasers should record, and keep on file, backup detailing which vendors were contacted, when they were contacted, support for the rationale in choosing the vendor. Management should implement a system of internal controls for this process. Planned Corrective Action: Shloma Weiss, Administrative Director, will establish and implement a process for documenting the procurement history and establishing a system of internal controls.

MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. Currently, the District has contracted with J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately.

Procurement Policy Action taken in response to finding: In response to the above finding related to procurement the staff team at the organization has already researched the procurement requirements and developed a policy to comply with Uniform Guidance. The policy was reviewed by all our department leaders and feedback was collected from our finance committee and implemented into the policy. The new procurement policy was presented to our Board of Directors at the same meeting as our 2023 Financial Statement Audit (May 30, 2024) and was reviewed and approved. Following approval of the policy by the Board of Directors the CFO will hold one or multiple meetings with NeighborWorks Green Bay’s leadership team to present the changes in the policy and plan any process adjustments needed to comply with the updated policy. The new policy and process changes will then be presented to all staff and specific changes will be shared then and worked through during individual team meetings for all departments to ensure the new policy is understood and will be complied with. The approved vendor list will also be developed and finalized. We expect that the new policy will be in effect and followed for all purchases within 90 days of our Board’s acceptance of the 2023 Financial Statement Audit and this corrective action plan. Since this policy will be new to our organization, the CFO will review procurement documentation in detail for all purchases over the micro-purchase threshold of $10,000 for the first three months following the implementation of the policy and then conduct a review on a sample of transactions thereafter through the end of 2024. Any deviation from the policy will result in additional training with the entire staff or specific department as applicable.

Finding Summary: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids were not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Responsible Individuals: Andre Stringfellow, CFO Corrective Action Plan: Procedures will be developed and staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation. Anticipated Completion Date: August 2024

Management concurs with this finding. Management is reviewing and revising its procurement policies to comply with state and local laws, the standards of the CFR, as well as reflect current operating procedures.

Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements. The City has initiated to hire an adequate amount of staffing which will allow the Purchasing Department to enforce the suspension and debarment process during the procurement process; which will include checking sam.gov and other appropriate federal resources to check for vendor suspension and debarment.

1. The District will obtain more information from the Ohio Purchasing Council going forward on future projects. 2. On the purchase of a used van, the transportation supervisor searched for a van that would suit the needs for our school district. 3. Our maintenance supervisor received 2 quotes for the floor scrubbers that we purchased. The district split the order between the two vendors.

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all ARPA funded organizations have not been debarred, suspended, or otherwise excluded from receiving federal funds prior to receiving ARPA summer program funds. The results of the search will be included in the ARPA spreadsheet. Responsible Person: Viridiana Carvajal, Co-Executive Director, and American Rescue Plan Act (ARPA) Compliance Contractor Anticipated completion date: May 10, 2024. This action already has been implemented for the 2024 ARPA summer program.

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implement formal procurement procedures aligned with federal regulations, including thresholds for prior‐purchase authorization and vendor checks for suspension and debarment. Staff training will be conducted to ensure competency, and oversight mechanisms will be strengthened through regular monitoring and integration of SAM verification processes. Comprehensive documentation and record‐keeping practices will be established, with periodic reviews to facilitate continuous improvement. Through these actions, the YWCA aims to enhance compliance with federal procurement standards and ensure transparent and accountable procurement practices.

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