Corrective Action Plans

The Council began a building renovation project before it became aware that funds were available to support the project. Therefore, the Council was not able to comply with regulations at the time of project design, bidding, planning, and construction. In addition, the Council’s project was only partially funded by the Coronavirus Recovery Funds, the majority of the project was funded through the Council’s fundraising efforts. Management agrees with the finding and is in the process of implementing the recommended procedures for future projects.

Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon training completion, the team will provide the Finance Committee of the Board of Directors suggested updates to our current policy.

Management Comments and Corrective Action: During the course of the single audit for the year ending August 31, 2022, it was noted that SWK "legacy" contracts did not follow the established procurement policy and procedures which requires SWK to obtain quotes from at least three sources and/or did not document the quotations in the procurement file for one expenditure between $25,000 to $100,000. This instance of noncompliance noted was for a consumer goods (i.e., clothing, and personal healthcare). Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized an existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization, hired new procurement leadership and invested Full Time Employees (FTEs) to develop a robust procurement department. As a result of this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provided tools for the selection of the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2023. Person Responsible for Corrective Action: Fred Muniz, CFO 2023

Item: 2022-004 Assistance Listing Number: 21.027 Programs: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Arizona State Office of the Governor; Maricopa County Pass-Through Grantor Identifying Number: Unknown Award Year: January 1, 2022 to December 31, 2024; January 28, 2022 to June 30, 2023 Criteria: In accordance with 2 CFR § 200.318 - General procurement standards - the entity must use its own documented procurement procedures which reflect applicable. State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR § 200.318. Condition: The entity does not have a documented procurement policy and procedures that address the provisions of 2 CFR § 200.318 Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: Completed Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will document in writing its previously unwritten policies and procedures to ensure adherence to the procurement policies that conform to 2 CFR § 200.318.

The County Council and County Executive will work through the Audit Committee and Policy Review Committee to review, update, and strengthen policies and internal controls related to County and Federal procurement policies. The County will provide sufficient training and resources for staff to make sure all County and Federal procurement policies are followed correctly. The County will also monitor these processes through internal audit procedures

Views of Responsible Officials: SAMU had a workshop for procurement practices together with Project Hope back in October/November 2022. The procurement process of Services and (nonrecurring) Goods has been updated in May/June 2023. Therein all the requirements were explained to fulfill the procurement standards established by 2 CFR 200.318. In the meantime, all procurement specialists have been advised to request a minimum of three formal quotes for procurements above $10,000, once those have been received and a proposal with an explanation (via email) of why a certain vendor has been preselected to provide the services and goods in question. With this information, the MD and Finance/Admin head are asked for internal approval and process the procurement of the Services and Goods. The approval is provided by email. An updated procurement policy is in preparation, the procurement process will be discussed again in another workshop in Q1 2024.

Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. 2. Mary's Center will document in the procurement files some form of cost or price analysis made in connection with every procurement action. 3. For any contracted service (other than equipment-specific technical support), Mary's Center procurement file will include:  Basis for selection of the contractor,  Justification for lack of competition when competitive bids or prices are not obtained, and  Basis for award cost or price. 4. These records and files will be kept in accordance with Mary's Center's Record Retention and Document Destruction Policy.

Compliance Finding The City's procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In Fiscal 2023, policies and procedures for expending federal funds were updated to include requisite review and documentation of said review during the awarding of contracts and prior to submitting invoices for approval.

FA 2022-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: $474 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: The School District has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2023 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

FEDERAL AWARDS – CORRECTIVE ACTION PLAN REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT – MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) 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: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition/Context: Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division must maintain records sufficient to detail the history of procurement. These records should 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. Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Denise Watters, CEO Anticipated Completion Date: December 2023 Planned Corrective Action: The Club will take immediate steps to strengthen its internal controls related to procurement of goods and services. This includes the revision of our written procurement standards to align them with federal regulations and guidelines. Additionally, we will establish procedures for maintaining adequate supporting documentation that demonstrates compliance with federal procurement standards. To ensure compliance with the prohibition on contracting with suspended or debarred parties, we will verify the status of entities with whom we enter into covered transactions using methods such as checking the System of Award Management (SAM) or collecting certifications. Responsible officials will oversee the plan's implementation, and we will maintain comprehensive records to demonstrate our commitment to adhering to federal procurement regulations and guidelines. This corrective action plan is vital to achieving and sustaining compliance with federal procurement standards.

Finding ref number: 2022-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal requirements for procurement, and suspension and debarment requirements. Name, address, and telephone of District contact person: Mark Prugar, President P.O. Box 2593 Friday Harbor, WA 98250 (317) 509-5952 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). CPWD will revise the District’s Policy 005 “Bids and Purchase” to add a specific section for all procurements that utilize Federal Funds to also include references to 2 CFR 200.318-327. Furthermore, Policy 005 will be revised to ensure that the District employs procedures (e.g. SAM investigation, contractor certification, or contractual clauses) to verify that perspective contractors are not suspended, debarred, or otherwise excluded from participating in federal programs when contracting for Goods and Services in excess of $25,000 in value. Anticipated date to complete the corrective action: Formally adopt revised Policy 005 at next Commissioners’ meeting – 18 October 2023

Action taken in response to finding: A Federal Procurement Checklist which addresses the above finding has been distributed to all County departments who receive grant funding. The County will implement this Checklist into its internal County Procurement Ordinance, Procurement policies & Procedures, and Grant Administration forms. Name(s) of the contact person(s) responsible for corrective action: Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: November 30, 2023

Action taken in response to finding: We will supplement our procurement policy to address requirements specific to federal awards. Name of the contact person responsible for corrective action: Renee La Fleur Planned completion date for corrective action plan: October 2023 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Renee La Fleur at 414-930-9210.

Corrective Action Plan for the Calendar Year Ended December 31, 2022 In response to the finding from the Federal single audit for the fiscal year ended December 31, 2022. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2022-002 - Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will strengthen its processes and internal controls to ensure the report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards. Christopher Caulfield, Executive Director of Financial Operations, will implement the corrective action plan, which is anticipated to be completed by December 31, 2023. caulfieldc@sihmc.org 973-754-2016

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 completeion is May 31, 2024. Update its procurement policy to ensure compliance with state requirements. Estimated time for completion November 30, 2023.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Renton January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the City for findings reported 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 City’s internal controls were inadequate for ensuring compliance with procurement and suspension and debarment requirements. Name, address, and telephone of City contact person: Kristin Trivelas, Fiscal Services Director 1055 S Grady Way, Renton WA 98055 (425) 430-6929 Corrective action the auditee plans to take in response to the finding: • The City will strengthen its policy and procedures that govern the use of federal funds to ensure they reflect local, state and federal procurement requirements; compliance to these guidelines shall be organization wide and will seek to ensure that there is a uniform understanding across multiple departments who may have federal funding resources. • When possible, the City will get approval from awarding agencies of all contracts and procurement processes prior to entering contracts that will or may be funded by federal grants. • Procedures will be updated to ensure that contractors and consultants working on federally funded projects are not suspended or debarred by requiring documentation in the form of one or more of the following: documentation of City staff search results for suspension and debarment status, stand-alone certification from the contracting entity, and/or a certification clause within the contract with the entity. • The City will conduct federal grant training workshops to educate staff on uniform guidance, to include the varying levels of federal procurement and associated requirements and documentation; the City will mandate completion of training before employees are authorized to seek or manage federal grants Anticipated date to complete the corrective action: 09/30/2024 and ongoing

Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented]

Stevens County January 1, 2021 through December 31, 2021 This schedule presents the corrective action planned by the County for findings reported 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: 2021-001 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal procurement requirements. Name, address, and telephone of County contact person: Lori Larsen, County Auditor (509) 684-7511 215 S Oak St. Colville, WA 99114 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 non-concurrence). Stevens County will review and update the County's procurement policies to be compliance 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). Anticipated date to complete the corrective action: December 1, 2022

CONDITION: The City of McKeesport contracted with Applied Concepts, Inc. for police trailers, and A&H Equipment for the purchase of a vactor truck. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. Both 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 two contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources.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.

Persons responsible for corrective action: Bob Harmon, Superintendent Corrective Action: The School implemented an electronic procurement system. This system provides clarity with the documentation and approval of procurements. The transition from paper to digital formats will provide enhanced internal controls to ensure that procurement transactions are documented and approved. Training will also be provided to staff involved with the procurement process to ensure that all are informed with the Federal and School requirements. Implementation date: June 30, 2025

Preparation of written federal procurement procedures for compliance purposes

2021-002 Special Education Cluster - CFDA No. 84.027 and 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 with a start date of 7/1/2022.

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 ref number: 2021-002 Finding caption: The Town did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of Town contact person: Randy Kilmer, Clerk Treasurer PO Box 278 Twisp, WA 98856 (509) 997-4081 Corrective action the auditee plans to take in response to the finding: The Town of Twisp agrees with the findings as presented and has committed to adopting policy as recommended by the State Auditor’s office in accordance with the BARS manual, implementing internal controls for federal expenditures and annual reporting. As this audit occurred in the 2023/24 fiscal year, it will not be possible to have these changes in place in at the time of this audit. Anticipated date to complete the corrective action: No later than 12/31/24