Corrective Action Plans

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.

Action Item Title 2022-003 – Procurement Policies and Covered Transactions Compliance Requirement Procurement, Suspension, and Debarment Status (Open: In-process) Condition: General Procurement Standards - Written Policies – The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements. Suspension and Debarment - Covered Transaction – From a population of nineteen disbursements, we selected nine disbursements to ascertain compliance with 2 CFR section 180.220 by examining the procurement documents provided by the Corporation. From that sample, we identified nine instances in which the SAM.gov registration verification process was not performed. Of the nine instances, we found eight suppliers properly registered, but one supplier appears as validated as unique and existing but not registered in SAM.gov. Identified root cause: Lack of understanding of procurement compliance requirements for federal awards. Fiscal year 2023 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs Grantee resolution plan: General Procurement Standards - Written Policies – With the implementation of Law No. 73 of 2019, previous processes established by regulation are repealed and rendered ineffective. In addition, the Corporation will adopt procurement policies in compliance with the federal regulations. Suspension and Debarment - Covered Transaction - Currently, the Corporation is verifying and requesting all suppliers with contracts of $25,000 and over with evidence of being active at SAM.gov. Also, the Corporation is verifying if the supplier is suspended or debarred to do business with the Federal government. Completion Date: General Procurement Standards - Written Policies – By June 30, 2025 Suspension and Debarment - Covered Transaction – Corrected in FY2023. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

Finding 2022-003 Finding Summary: In testing of procurement, suspension, and debarment, the auditors noted that the City’s procurement policy followed state law which is some cases is less restrictive than federal law. They also noted that the policy does not include the required contract provisions that are needed in contracts with federal grants. Responsible Individuals: Douglas Heinrich, Finance Officer Corrective Action Plan: We will assess if we need to adopt a policy for procurement if we receive federal grants in the future. We will be aware of the contract requirements to ensure they are included in contracts which involve federal money. Anticipated Completion Date: December 31, 2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Stevens County January 1, 2022, through December 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 US. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The County's internal controls were inadequate for ensuring compliance with federal procurement, suspension and debarment requirements. Name, address, and telephone of County contact person: Jill Jacobs, Chief Deputy Auditor 215 S. Oak St, Colville, WA 99114 509 684-7549 Corrective action the auditee plans to take in response to the finding: 1) The County has drafted and adopted Resolution 85-2023 on July 17, 2023, addressing the federal procurement standards recommendation. 2) A staff member took training on federal procurement standards and processes related to FEMA recovery efforts after a disaster and has shared the documents and training aids with staff that do federal procurement. Further, review with several staff was done related to this training to beef up internal knowledge and controls. 3) The County has trained staff on proper documentation and retention of documentation on suspension and disbarment. Further, the County is currently working on an internal policy on this subject. We expect to have this policy complete and adopted by May 31, 2024. Anticipated date to complete the corrective action: May 31, 2024

Finding 2022-002 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: 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. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2022, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds. Questioned Costs: Unknown Cause: Weaknesses in the design and operation of controls. Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable. Identification as a Repeat Finding: Yes, finding number 2021-002 Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Managements Response: The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326 Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2024 Action Taken: Procurements are conducted in accordance with Acushnet’s Federal Grant Procedures Manual which abide by Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from four (4) vendors - CJAWS, Inc., Edmentum, Inc., Savvas Learning Company, and Technology Resource Advisors, Inc. This is a repeat finding (2021-007) from the previous fiscal year for CJAWS, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records 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. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. Particularly as it relates to procurement procedures, for acquisitions of property or services in which the aggregate dollar amount is greater than the micro-purchase threshold but does not exceed the simplified acquisition threshold, the District will obtain and document price or rate quotations from at least three qualified sources. In addition, management of the District will obtain training where available and applicable to enhance their internal controls over the management of federal program funds. The District’s timeframe for implementation is effective immediately.

Corrective Action Planned: The City Clerk and Mayor, with help from the Treasurer, will develop and implement documented procurement procedures that conform to the procurement standards relating to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.317 through 200.327 Name(s) of Contact Person(s) Responsible for Corrective Action: City Clerk, Kami Hoerning. City Treasurer, Karen Kipp. City Mayor, John McGinley. Anticipated Completion Date: Summer 2024

The Wilmington Land Bank is working to rectify the deficiency identified in the procurement policy and procurement action documentation finding. The Land Bank has committed to adopting a written procurement policy that will comply with federal requirements in 2 CFR Part 200 Subpart D as well as any local and state requirements. Becky Vogel, the Land Bank’s Director of Finance will create the policy, the Land Bank’s Finance Committee will review the policy, and the Land Bank’s Board of Directors will adopt the policy no later than the August 1, 2024 Board of Directors meeting.

FINDING 2022-005Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: We will provide additional training to our Food Service team about the processes with suspension and debarment. We had assumed we had done enough due diligence since we passed our IDOE Child Nutrition audit; on the same token that audit may not have encompassed the sample that was randomly selected by CLA. We will also add suspension and debarment language into any other contract we anyone that we enter where there is a chance that Federal Dollars could be used for the purchase.Anticipated Completion Date: ASAP

REFERENCE: 2022-018 ? Procurement and Suspension and DebarmentResearch and Development Cluster (12.420, 93.103 and 93.853)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Corrective Action Plan: Training was provided to program and operations managers to add additional documentation to requisitions. An updated work instruction will be developed by the research administration department outlining the necessary documentation for non-competitive purchases.Person Responsible: Sheri Sanders, Division Director Research AdministrationExpected Completion: April 2023

FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Service Program, COVID-19 ?Summer Food Service ProgramALN Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Chad Yencer - SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:BCS has established the following internal controls to ensure compliance:1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, thesuperintendent will require that any vendors selected are in compliance with theProcurement and Suspension and Debarment compliance requirement by completing one ofthe following quality checks with each vendor prior to purchase:a. Checking the federal System for Award Management (SAM) database athttps://sam.gov/content/exclusions and maintain a screenshot of the search results.b. Collect a certification from the vendor directlyc. Add a clause or condition to the covered transaction with the vendorAnticipated Completion Date:This corrective action will be implemented and completed immediately with any purchase made that meets theabove threshold.

Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retainedfor audit purposes.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding This finding was a result of only one vendor being availableat the time. The Office of Purchasing and Grants staff will comply with the requirement forobtaining quotes and document any exceptions if two quotes cannot obtained.Name(s) of the contact person(s) responsible for corrective action: BCPS Office ofPurchasing staff, grant accountants/fiscal staff.Planned completion date for corrective action plan: For immediate implementation andongoing.

Finding 2022-002 - Procurement, Suspension and DebarmentMaterial Weakness in Internal Control over ComplianceFinding Summary: As part of the audit, Eide Bailly LLP identified that the formally documented policy didnot include many of the necessary procurement provisions. Provisions include a consistent control in placeto check applicable vendors for potential suspension and/or debarment for covered transactions. Inaddition, current controls are to be documented to provide for a proper audit trail.Responsible lndividual(s): Chief Financial OfficerCorrective Action Plan: The policy has been updated to include all federal requirements regardingprocurement controls and suspension and debarment controls as proposed by the auditors. Managementwill retain documentation to support that the control process was followed.Anticipated Completion Date: Ongoing

Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: The College will implement training and procedural changes during the grant budgeting process and in the post-award process to ensure documentation of reasonable prices and rates to include training related to handling vendors who may be used across multiple funding sources.Name of the contact person responsible for corrective action: Tess Powers, Director of Faculty Research Support (719) 389-6318Planned completion date for corrective action plan: May 1, 2023

Recommendation: The auditors recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, they recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Planned Corrective Action: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.Name of Responsible Party:1. Dr. Andrew Sund, President2. Thomas Richter, VP of Administration/CFO3. Melissa Hill, Interim Provost4. Corey Hodge, Interim VP of Academic AffairsAnticipated Completion Date: June 30, 2023

Federal Agency Name: Department of State ? Bureau of Population, Refugees, and MigrationProgram Name: Oversees Refugee Assistance Programs for AfricaCFDA #19.517Federal Agency Name: Agency for International DevelopmentDepartment of StateProgram Name: USAID Foreign Assistance for Programs OverseasCFDA #98.001Finding Summary: CVT has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, CVT was not testing vendors for suspension and debarment.Responsible Individuals: James Behnke, CFO and Mary Kinder, ControllerCorrective Action Plan: Management will maintain adequate supporting documentation and records to document history, methods of procurement, and documentation to support check for suspension and debarment. This will be maintained for all formal written vendor contracts.Anticipated Completion Date: July 2023