Corrective Action Plans

Program: Coronavirus State Local Fiscal Recovery Funds (SLFR) CFDA No.: 21.027 Federal Grantor: U.S. Department of Treasury Passed-through: Fresno County Award No. and Date: Fresno County Agreement 22-126, April 5, 2022 Finding 2022-003: Procurement & Suspension and Debarment Type of Finding: Material weakness in internal controls over Procurement & Suspension and Debarment and Noncompliance View of Responsible Officials: Concur with the finding. Corrective Action Plan: ? The District will establish written procurement policies and procedures as required by the Uniform Guidance (2CFR Part 200). ? The District will implement the following internal controls: 1. Review the Uniform Guidance and update the current policies and procedures to include all the requirements not part of the District?s current policies. 2. Make available the updated policies and procedures to responsible management and employees. 3. Management should monitor compliance and performance with the policies and procedures. Projected Implementation Date: June 30, 2023 Name of Responsible Person/Contact: Josh Chrisman, Administration Officer

Finding 2022-001 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund - Institutional CFDA # 84.425F Finding Summary: In the testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Responsible Individuals: Tonya Sletto Corrective Action Plan: Based on the limited amounts of Federal Awards received by the University that require procurement procedures to be applied, the University was not aware of the formal policy requirements under Uniform Guidance. We will work to adopt a policy for procurement policy that includes the requirements noted under Uniform Guidance and use that policy when federal money is being spent. Anticipated Completion Date: October 31, 2022

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the Town establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town of Easton will modify the current procurement procedures to add an additional section for those services, materials or products procured that have a Federal Grant Revenue source. Name(s) of the contact person(s) responsible for corrective action: Donald Richardson Planned completion date for corrective action plan: June 30, 2023

Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) CFDA No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Repeat Finding from Prior Year: Yes, prior year finding 2021-09. Management?s or Department?s Response: We Concur. Views of Responsible Officials and Corrective Action: Procedures have been developed and implemented to comply with the County?s policies over procurement and suspension and debarment. Name of Responsible Person: Bruce Cosby Name of Department Contact: Bruce Cosby Projected Implementation Date: July 1, 2023

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out 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: Laura Clark, the Director of Finance, is currently developing a procurement and related conflict of interest policy. These policies will be presented to the Board of Directors for approval at the July 2023 board meeting. Name of the contact person responsible for corrective action: Laura Clark, Director of Finance Planned completion date for corrective action plan: July 2023

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-003 Description of Finding Procurement and Suspension and Debarment 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action EASTCONN?s Executive Director and the Board of Directors will review, revise, and approve an updated procurement policy to incorporate required elements of the Uniform Guidance related to expenditures funded with Federal Grants. Name of Contact Person Eric S. Protulis, Executive Director Projected Completion Date November 2023

Assistance Listings number and program name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2023 Corrective Action Plan: The County procurement officer will, in collaboration with responsible departments, follow County policies and procedures for determining and documenting each sole-source procurement including documenting the good-faith search for available sources, concluding a single source, and including the related documentation in the contract file. The Procurement Officer and departments responsible for procurement will participate in annual training about County policies and procedures regarding the determination and documentation of sole-source procurement.

2022-002 PROCUREMENT ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: It is recommended the County ensure they follow their countywide policies regarding federal procurement and retain documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure they follow their federal procurement policy for purchases. Name of the contact person responsible for corrective action plan: Lindsey Meyer, Finance Director Planned completion date for corrective action plan: December 31, 2023

Finding 2022-002 Procurement Description of Finding The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326 and purchases were made that did not follow these requirements. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action: Corrective action will be taken to ensure the policy is updated and the correct procurement procedures are followed. Name of Contact Person: Edward B. St. John (475) 473-3352 Projected Completion Date: June 30, 2023

Finding No. 2022-007: Procurement Policy - Material Weakness in Internal Control Over Financial Reporting U.S. Department of Health and Human Services, Health Center Program Cluster; CDFA No. 93.224 Condition: There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Recommendation: Marcum recommends that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. Marcum also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken: CCI is recommending to the board to update its procurement policy by obtaining at a minimum-three separate bids for anything above $50,000.00. We are also in the process of hiring a full-time purchasing manager to oversee procurement policy and strategy. Anticipated Completion/Implementation Date: End of fiscal year 2024.

Finding 2022-001 ? Suspension and Debarment Recommendations: The Board of Directors, the Director and key positions of management should re-assess the current board policy and potentially add encompassing compensating controls. The Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Action Taken: We agree with the recommendation and are set to re-address the board policy with board members, Business Director, Federal Funds Director, and Superintendent. Our targeted implementation date is March 2023.

Findings: 2022-003 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Findings: 2022-002 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Kittitas Reclamation District P.O. Box 276 Ellensburg, WA 98926 Phone: (509) 925-6158 Fax: (509) 925-7425 CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kittitas Reclamation District 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 U.S. 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 District?s internal Controls were inadequate for ensuring it complied with federal procurement requirements. Name, address, and telephone of District contact person: Stacy Berg PO Box 276 Ellensburg, WA 98926 (509)925-6158 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). Upon receiving the guidance on the current audit, the District would like to move forward by reviewing the procurement policy and making any necessary changes while working under the guidance of the SAO Procurement Specialist to ensure that an updated procurement policy continues to meet the needs of the District and the federal guidelines for federal funding. Anticipated date to complete the corrective action: September 30, 2023

Finding # 2022.001 Procurement and Suspension and Debarment Response Management acknowledges the condition related to following the organization?s procurement policy guidelines. Management is taking steps to correct this condition and has identified areas in the system that will be corrected in order to follow all Federal requirements related to procurement. For example, a member of the Finance department will complete procurement training at least once a year. The Finance Department will also train all Project Managers in Procurement Policies and Procedures as needed. Responsible Party David Ayala, CFO Estimated Completion 12/31/2023

FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. (See attachments)

Finding # 2022-001 Response Management agrees with the finding and recommendation and will update its procurement policy to comply with 2 CFR 200.318 through 2 CFR 200.327. Responsible Party Bobby Splinter Estimated Completion December 31, 2023

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the bestowal of federally procured recovery funds based upon relationship rather than merit. See, Mont. Code Ann. ? 2-2-301. To that end, the City shall draft and pass via majority vote of City Council Members a resolution to address this issue which complies with State and Federal regulation of said funds. Said resolution will be passed in 2023 prior to the conclusion of the City's fiscal year. Proposed Completion Date: Fiscal Year 2023.

The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.

Finding Number: 2022-001, 2021-001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Business Manager and Human Resources Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: Vendors will go through the suspension and debarment process and business office staff will assist with the process. Sealed bids will be conducted in accordance with the School policy, and the Human Resources Manager will keep documentation of the sealed bid process. The School?s procurement policy over quotes will be refined and followed. The Business Manager will review the process with business office team and department supervisors.

Finding No. 2022-001: Procurement and Suspension and Debarment ? Significant Deficiency (Program Level) Finding: During testing the Federation?s controls on compliance over procurement and suspension and debarment, the Federation could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Corrective Actions Taken or Planned: Management will update its procurement policy to ensure it is in compliance with Uniform Guidance requirements and will take the additional steps of updating the policy as changes in the Uniform Guidance requirements occur. Review and monitoring is effective immediately and will be on-going beginning January 2023 and is expected to be completed by February 2023

Recommendation: We recommend the County management establish internal controls to ensure compliance with federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finance department has met with the IT department to discuss federal procurement requirements and possible checklists. Name of the contact person responsible for corrective action: Lisa Malinski, Finance Director

The Fremont County Clerk is responsible for paying the bills for the county and was not aware that we should be verifying the vendors that they were not debarred, suspended, or otherwise excluded per 2 CRF 200.318(h) and 2 CFR 180. We will set a policy to use going forward, that will be attached to the voucher for these vendors showing that we have done our due diligence in these matters. The proposed policy is to work with the Commissioners (who approve contracts), accounts payable department and Treasurer on steps to verify the companies upon the receipt of their contract. Contracts are approved by the County Attorney, and once they are approved, I will add a step to have a member of our staff do the verification and attach a form stating the date and outcome of the verification prior to accepting the contract by the vendor.

Finding No. 2022-004: Procurement Policy ? Material Weakness in Internal Control Over Financial Reporting; U.S. Department of Health and Human Services, Rare Disorders: Research, Surveillance, Health Promotion, and Education; Assistance Listing Number 93.315 Condition There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures, no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Recommendation It was recommended that the Association establish a written procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. It was also recommended that a review of all existing vendor or sub-awardee contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken The Spina Bifida Association will take action to ensure an up-to-date Procurement Policy is approved by the Board of Directors. Anticipated Completion Date December 2023

The responsible officials within the Foundation acknowledge the findings from the 2022 audit related to our procurement practices under 2 CFR section 200.320. We understand the gravity of the situation, particularly considering that the Foundation did not have a formal procurement policy in place. To address the deficiencies identified in the audit, our planned corrective actions are foundational. Firstly, we will develop and implement a comprehensive procurement policy that adheres to the federal regulations specified in 2 CFR sections 200.318 through 200.326. This policy will provide clear and specific guidance on both competitive and noncompetitive procurement methods, establishing a framework for future procurement activities. Secondly, we recognize the paramount importance of robust documentation. Therefore, we will institute rigorous documentation procedures that mandate the thorough recording of the historical context and rationale for procurement decisions at the time of contract execution. This documentation will be meticulously maintained, adhering to the stringent requirements mandated by the federal regulations. Additionally, we will prioritize staff training to ensure that all personnel involved in the procurement process are well-informed about the new policy and are capable of consistently adhering to the documentation standards. These measures, including the creation of a procurement policy from the ground up, will enable us to rectify the audit findings promptly, establish compliance with federal regulations, and uphold the integrity of our federal award programs.