Corrective Action Plans

2022-004 Summary of Finding Missing documentation for procurement, suspension and debarment: Bid or sole source documentation was missing for all five contracts that we selected for testing and there was no documentation of the verification that the contractor was not suspended or debarred. It is important to determine that contractors used are eligible for work and that they have not been suspended or debarred from performing work on projects supported by federal funds It is also important to have full and open competition on contract work that is federally funded. As a result, the Organization was missing documentation relating to the requirements for procurement, suspension and debarment. Statement of Concurrence or Nonconcurrence This finding was concurred with due to staff turnover and the department being short-staffed. Corrective Action In response to the noted deficiencies in procurement, suspension, and debarment documentation, the Organization has developed a comprehensive Grant Cycle Standard Operating Procedure that aligns with OMB Uniform Guidance. This procedure reinforces the existing Procurement policy, ensures all staff receive targeted training on relevant requirements, and incorporates additional review measures into the onboarding process for new hires. Furthermore, a new position has been created, and a new management platform has been implemented to manage purchase orders, maintain all sourcing documentation, and verify all contractors are not suspended or debarred, thereby ensuring full compliance with federal requirements and promoting transparency in contractor eligibility and competitive bidding.

CONDITION: The City of McKeesport contracted with a third-party vendor (A&H Equipment) for the purchase of a street sweeper. The contract with the third-party vendor, which was procured through a cooperative purchasing group (COSTARS), exceeded the threshold for competitive procurement. The City was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the City did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds the Simplified Acquisition Threshold. The cost of the street sweeper exceeded the simplified acquisition threshold of $250,000. As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the City must maintain sufficient records to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance Simplified Acquisition, including such instances whereby the City is using a contract vehicle from a cooperative purchase network, that the City is in compliance with all applicable sections of the Uniform Guidance, in specific, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the City conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Sections 2 CFR 200.318(i) and 2 CFR 200. 324(a) of the Uniform Guidance.

CONDITION: The City of McKeesport contracted four (4) vendors for the purchase of seven separate purchases of equipment for the City. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. All of these purchases were procured through a cooperative purchasing group (COSTARS). The City was unable to 1) provide records sufficient to detail the history of procurement for these contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources. This is a repeat finding (2021-005) for the prior year. CRITERIA: Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the City must maintain sufficient records to detail the history of procurement. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200. 318(i) of the Uniform Guidance.

Finding Number: 2022-006 Condition: Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarment rules. Planned Corrective Action: Management will implement written policies and procedures over procurement, suspension, and disabarment that conform with Uniform Guidance Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: 06/30/2025

Assistance Listing Number 21.027 Noncompliance Over Procurement and Suspension/Debarment - Major Federal Program - Coronavirus State and Local Fiscal Recovery Funds Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended. This includes that all expenditures are properly documented and that all vendors are ferderally eligible to perform services

2022-004 Procurement Criteria: The Town must follow the procurement standards set out at 2CFR Section 200.318 through 200.326. This requires bids to be obtained for purchases ranging from $10,000 - $250,000. The Town currently has policies in place to utilize the state library which is a listing of approved vendors for potential purchases of over $50,000. The CFR does allow an entity to increase the lower limit from $10,000 to $50,000 in certain circumstances. One of the conditions is that the entity qualifies as a lowrisk entity. The Town currently does not qualify as low risk; therefore, the Town does not qualify for the increase of the lower limit from $10,000 to $50,000. Sole source vendors are the exception to this rule. Condition: The Town did not obtain three bids for over $10,000 purchases. Did use the state library to identify eligible vendors but failed to obtain the required three bids. Cause: The Town relied on the state library which is not an approved listing according to the CFR. Effect: The Town is not in compliance with 2CFR Section 200.318 through 200.326 and therefore, the Town has the possibility of not being able to renew contracts in the future. Recommendation: We recommend that the Town obtain the required three bids for purchases over $10,000. Views of Responsible Officials and Planned Corrective Actions: The Town has hired an Asset Support Specialist to help ensure compliance with such requirements and understands the importance of meeting the requirements.

Contact Person Dan Juve Planned Corrective Action The District will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of fiscal year 2023.

As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.

Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.

Management concurs with the audit finding. The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where City personnel are not available or qualified to perform.

The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The City will develop written standards of conduct in that satisfy the requirements of 2 CFR § 200.318(c)(1).

County Commission gave former County Manager direction to consult with legal counsel to determine premium pay for County staff who worked throughout the Pandemic. A meeting was held between Former County Manager, Financial Specialist, County Sheriff and VMDC Warden to discuss premium pay for all staff as well as public safety recruitment and retention. Former County Manager stated after consulting with County Legal Counsel and NMC General Counsel, all County staff including, Elected Officials were eligible to receive “premium pay” in compliance with the American Rescue Plan Act Rule. Financial Specialist and County Sheriff questioned the eligibility for Elected Officials to receive premium pay referencing N.M. Const. Art IV, section 27 “No law shall be enacted giving any extra compensation to any public officer, servant, agent or contractor after services are rendered or contract made; nor shall the compensation of any officer be increased or diminished during his term of office, except as otherwise provided in this constitution.”, and NMSA 4‐44‐4.1 related to County Elected Official Salary caps. Former County Manager responded premium pay should be issued to all staff including Elected Officials through the accounts payable department instead of payroll to avoid violating New Mexico Constitution and State Statute and premium pay is not considered a salary increase but “premium pay” outside of regular salary paid to “essential workers”. Former County Manager went on to explain that all law enforcement officers were eligible for premium pay because they were described as “essential” within the American Rescue Plan Act Rule. In a regular Commissioner Meeting held on 10/12/2021 Former County Manager presented to Commission and recommended approval of public safety recruitment and retention plan as well as a one‐time payment to current staff of $5,000 who worked from January 2020 through October 2021 and a prorated rate be awarded to any employee that worked a portion of that time. She also stated new information was received that confirms all County employees are eligible for the premium pay, currently 88 employees. She also stated that public health contractors are also eligible for premium pay and recommended payment be made to 2.5 full time positions to contracted health care services provider. Commission approved the request from the Former County Manager based on her recommendation. Former County Manager drafted, reviewed and approved a list of employees scheduled to receive payment including 5 contracted medical service provider including the CEO of the company. Former County Manager directed accounts payable clerk to issue payment through accounts payable. On November 8th 2021, Former County Manager presented to and recommended approval additional premium pay be awarded to Employees that had retired and worked part of the period of January 2020 though October 2021 and two full time Employees that were laid off. In January 2022 Elected Officials requested a meeting be held to discuss the issuing of 1099 forms to employees who received premium pay. Also present in the meeting was Commission Chairman. Elected Officials raised concern that staff was issued a 1099 and questioned if this was correct. Former County Manager informed staff the advice the County got was to issue a 1099‐NEC, under the circumstances. However, upon review of email communication former County Manager received an opinion from her personal Tax Accountant stating that the payments should have been run through payroll and recommended Former County Manager either correct the original error and would require several steps including corrected 941’s and corrected w‐2’s or issue a 1099 NEC. Former County Manager directed accounts payable clerk to issue a 1099 NEC. Commission Chairman questioned several expenditures from American Rescue Plan Act Fund, including the additional 2 full time positions and CEO of the company not approved by Commission, it was later determined that several expenditures were not allowable under the American Rescue Plan Act Fund Rule. Colfax County Staff submitted written report to Office of the State Auditor as required under NMSA 1978, Section 12‐6‐6 (criminal violations) an agency or auditor shall notify the state auditor immediately, in writing upon discovery of any violations of criminal statute in connection with financial affairs. Former County Manager announced her resignation February 28, 2022. It was later discovered through communication with County legal Counsel and NMC General Counsel that Former County Manager mislead the County Commission, Elected Officials, and County Staff and did not consult with County Legal Counsel or NMC General Counsel as previously stated and as directed by the Commission before making recommendations for approval of American Rescue Plan Act Funds.

Finding Number: 2022-004 Condition: WakeMed does not have a written policy in place over procurement methods which covers 2 CFR 200.317 - 200.327, nor did WakeMed follow required procurement guidelines. Planned Corrective Action: WakeMed is in the process of updating their existing procurement policy to include the relevant sections from the Code of Federal Regulations and will provide education to the areas involved in procurement and use of federal funds on these requirements. Contact person responsible for corrective action: Lynn Bailey Anticipated Completion Date: 12/5/2024

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $189,893 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Management has implemented internal controls procedures to ensure transactions are properly processed and reported. Additional procedures have been established to review transaction to make they align with the approved budget. Estimated Completion Date: June 30, 2024 Contact Person: Georgette Evans Telephone: 478-374-3783 Email: gevans@dodge.k12.ga.us

Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the serious nature of this finding and the compliance required with 2 CFR sections 200.318 through 200.327, as well as Part 1326 for vendor exclusions. The Interim Controller and Director of Finance will be revising procedures to document requirements for all procurement activities, regardless of type. We also understand these findings are repetitive from the 2021 audit; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2022 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. Resolution of this issue began in 2024 as staff were trained and provided the updated procedure to ensure all procurement activities adhere to the company policies. Continuing education will be provided in 2025 to ensure continued compliance with these policies. In 2025, a formal procurement system in the new ERP structure will be implemented and utilized for vendor quotes, requisitions and POs to ensure compliance. Periodic reviews of the procurement activities will be performed to ensure compliance with these procedures to mitigate the risk of continued deficiencies. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: December 2024

The College will retain all procurement documentation going forward.

AIRS management has started the process of creating new and updated policies and procedures related to financial reporting, activities, including written procurement standards, written standards of conflict of interest and others as required under Uniform Guidance

2022-002 Special Education Cluster - Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures to maintain records sufficient to detail the history of all procurements be strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As of 7/1/2022, Framingham Public Schools will no longer claim the Massachusetts Chapter 30B SPED exemption (Appendix A. #8 & #22) for any SPED contracts being paid with federal funds. Instead, these contracts will be subject to the standard Chapter 30B procurement policies. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, will meet with Director of SPED, Laura Spear, and City of Framingham Chief Procurement Officer, Jennifer Pratt, to make them aware of this finding and request that 1) all SPED grant funded contracts going forward will follow standard Chapter 30-B procurement policies and 2) City of Framingham updates their accounting procedures/procurement policies to reflect this change by 7/1/2022. Name(s) of the contact person(s) responsible for corrective action: Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress

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: • PDA worked with Clark Nuber team to revise and update the procurement policy to be in-line with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards procurement standards. Anticipated completion date: Third quarter 2024 Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Directors, Finance team

Finding No. 2022-006 KCHC agrees and acknowledges the findings related to procurement and suspension and debarment compliance. Since the hiring of new procurement personnel in September 2024, the Finance head has been actively providing regular training to procurement and finance staff, ensuring they are well-versed in federal regulations. Additionally, KCHC has implemented enhanced systems for procurement management and documentation. 1. Onboarding and Training for New Procurement Personnel: The new procurement personnel will undergo comprehensive training on KCHC's procurement policies, federal regulations (2 CFR Part 200), and the use of ProcurementExpress and DocuSign systems. This training ensures the new staff member adheres to procurement procedures, including proper documentation. 2. Ongoing Training for Procurement and Finance Staff: Regular training sessions are conducted to reinforce awareness of federal procurement regulations and KCHC’s internal policies. The focus will be on maintaining adequate documentation, ensuring open competition in procurement processes, and complying with suspension and debarment regulations. 3. Strengthening Monitoring and Internal Audits: KCHC will continue to enhance internal monitoring and audit activities. The Finance department will collaborate with procurement personnel to review all transactions, ensuring that procurement packages include price quotes, purchase orders, and contracts as required. Internal audits will be performed regularly to identify and rectify any documentation gaps. 4. Optimizing Existing Systems: The integration of ProcurementExpress with the accounting system and the use of DocuSign for approval routing will be fully utilized to ensure that all procurement steps are documented and compliant with federal standards. These systems will also ensure that records are readily available during audits. 5. Addressing Repeat Findings: To address the repeat nature of this finding, KCHC will closely monitor the implementation of corrective actions. The accountant will lead efforts to track procurement documentation compliance, providing regular reports to CFO to ensure that procurement activities align with both federal and internal requirements. Implementation Timeline: Completed as of September 30, 2024 with continued updates and monitoring. Responsible person: Arlene Deleon Guerrero, CFO

Department of the Treasury, Passed through North Dakota State Water Commission Federal Financial Assistance Listing 21.027 COVID-19 - Coronavirus State and Local Discal Recovery Funds Procurement, Suspension, Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: General Manager (Vacant) and Jan Lee, Office Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements Anticipated Completion: December 31, 2024

Corrective Action: Management of the Institute did not provide any planned corrective actions for this finding. Person Responsible: Management of the Institute did not identify an individual responsible for corrective action for this finding. Completion Date: Management of the Institute has not established a completion date for corrective action for this finding.

Finding ref number: 2022-003 Finding caption: The District did not have adequate internal controls to ensure compliance with federal procurement requirements. Name, address, and telephone of District contact person: Dana Fox 210 Government Road Mattawa, WA 99349 (509) 932-4499 Corrective action the auditee plans to take in response to the finding: The District is committed to following all State and Federal procurement standards in its solicitation to secure goods and services. As indicated in the District response, the procurement of both items presented unique circumstances that affected the solicitation of a contractor for the renovation (project size) and a vendor to supply the specialty good. The District believes due diligence was followed in each procurement action through thorough research and cost benefit analysis prior to making a vendor selection. The District will ensure staff participate in the recommended State sponsored procurement training. Estimated time for completion: May 31, 2024. Update its procurement policy to ensure compliance with State requirements. Estimated time for completion: November 30, 2023. Anticipated date to complete the corrective action: Listed above, but final completion by May 31, 2024.

Federal Program Name/Assistance Listing Title: Federal Transit Cluster Federal Assistance Listing Number: 20.507 State Program Name: State Urbanized Area Formula Program, State Formula Grants For Rural Areas Contact Person: Ted Ross, Acting Executive Director Anticipated Completion Date: 1/1/2025 Planned Corrective Action: The Transit District has changed most of the personnel in Finance and Administration, which improved expertise and performance. The Transit District is also working on a new comprehensive Finance and Administration policy which will include all new controls implemented. Procurement procedures will be updated and strengthened in the new policy including ensuring documentation of quotes and suspension and disbarment are checked, reviewed, and documented in the procurement file.