Corrective Action Plans

2024-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the Village evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The Village immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Ryan VanDeWalle, Village Administrator and Melanie Wiskow, Finance Director/Treasurer Planned completion date for corrective action plan: The Village immediately began evaluating procedures and will implement as soon as possible.

2024-004 Coronavirus Relief Funds – Assistance Listing No. 21.027 Recommendation: CLA recommends the City review procurement policies for the entire City to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will review procurement policies for the entire City to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Name of the contact person responsible for corrective action: Tammy Kasal, City Clerk/Treasurer Planned completion date for corrective action plan: December 31, 2024

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i), 200.320(a)(2)(i) and Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for future purchases where applicable.

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Voyager Sopris Learning ($49,117) and Questeq ($70,549). CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

Annual July 1 filing of the Request for Approval for a Noncompetitive Proposal when Procuring Personnel-Based Services from a High-Performing Educational Service Center Under Ohio Revised Code 3313.843(J). This form was filed when I spoke with Adam and became aware of the oversight. The request was received and accepted by DEW for the period March 31, 2025-March 30, 2026. Moving forward the form will be filed for July 1 start date:

In the future the Treasurer will ensure proper procurement methods are utilized.

The district will obtain more information from the Ohio Purchasing Council going forward on future projects.

The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2024-2025 fiscal year.

Although procurement will be handled through several manager, MVRTD will implement a procedure that All procurements will be finalized and filed with the procurement manager. MVRTD will update it procurement policy to restate the timetable for operational procurements and define the filing of the documentation of each operational procurement above a specific dollar value ( to be defined).

Revise and standardize the Sole Provider Justification form to require all federally mandated elements under 2 CFR 200.320. Train all staff involved in procurement activities on the updated requirements and documentation standards. Implement a review and approval step within the new ERP system to verify that all sole-source procurements meet the full documentation standards before processing. Conduct periodic internal audits of procurement files to ensure continued compliance. Require management approval for any noncompetitive procurement exceeding micro-purchase thresholds.

2024-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2025 Corrective Action: Management agrees with the finding and recommendation set forth within. Prior to fiscal year 2024, noncompetitive procurements completed followed the prior procurement policy that did not align with Uniform Guidance as relates to noncompetitive procurement justifications. The Corporation has since completed its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. Training on the Uniform Guidance procurement requirements is now ongoing and is required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. NeighborWorks has also implemented a new contracts management system to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. During fiscal year 2025, management will implement additional controls to ensure expenses charged to federal programs on contracts entered into prior to fiscal year 2024 are in compliance with the procurement requirements of the Uniform Guidance. This process will involve reviewing all existing contracts that previously lacked compliant noncompetitive procurement justifications and implementing corrective actions as needed.

This error occurred during fiscal year 2022, when the architect for an upcoming project was chosen. We are in a very rural area, where architects are not easy to come by. For this project, we had decided to utilize a local firm we had a good track record with. We presented it to our board for approval, and it was approved by them at that time so we originally had thought we could justify with having them as a sole source vendor. At the time, the total amount of the project was unknown, and has even changed significantly since that date. However, come to find out, due to the size of the project it should have been bid out. We have revised our procurement policy since this date and have educated all staff on proper procurement procedures.

HCS currently has in place policy 2095-Procurement Standards, which requires obtaining 3 quotes for goods and services above $5000. This policy was not followed by the agency's leadership when the goods and services mentioned in this finding were procured, despite counsel recommending that it be followed. Corrective action included termination of the individual who violated policy. Beginning on 11/15/2024, the above-referenced policy has been, and will continue to be, adhered to.

Audit Finding Summary: 2024-002 The Organization did not establish or follow sufficient internal controls to ensure compliance with federal procurement requirements, including maintaining the required documentation for procurement activities. Corrective Action Plan: Contact Person Responsible for Corrective Action: Wendi Gephart, Federal Contracts and Grants Compliance Manager wendi@movementstrategy.org | (510) 956-3849 Planned Action: MSC recognizes the need for improved procurement documentation and internal controls. To strengthen compliance with 2 CFR 200.318-326, MSC will take the following actions. Revised Procurement Policies: MSC is updating its procurement policies and procedures to reinforce adherence to federal regulations, ensuring full and open competition in all procurement transactions. Enhanced Documentation and Record-Keeping: A comprehensive process will be established to maintain detailed procurement records, including justification for vendor selection, contract pricing, and competitive bidding results. This will ensure transparency and compliance with federal requirements. Staff Training in Federal Procurement Standards: MSC will provide training to staff on procurement regulations, including conflict-of-interest policies, documentation requirements, and competitive bidding procedures. Periodic Compliance Review: Internal review will be conducted periodically to verify compliance with procurement policies and federal regulations. MSC remains committed to continuous improvement in financial and compliance practices to uphold the integrity of its federally funded programs. Expected Completion Date: June 30, 2025

We will comply with the procurement policy. I have already submitted the information to ODEW for FY25.

Corrective Action Plan To comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a) the Board will obtain from multiple vendors on an animal basis price listings of commonly purchased items and or services to deternune lowest cost of items and or services available to be purchased from qualified sources. Anticipated Completion Date: April 1, 2025 Contact Person(s): John N. Godwin, Chief School Finance Officer

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Corrective Action Plan: The Authority acknowledges the finding and is currently working to correct this. Responsible Official: Contact person is Todd Shurn, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2025

CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding Reference Number Corrective Action Responsible Person Anticipated Completion Date Finding 2024-001: Internal Control Over Financial Reporting Because of its size, the City does not feel it is cost effective to hire an additional employee(s) with the experience, technical training and time to prepare its financial statements. Draft copies of reports are reviewed and approved prior to their issuance by management. As such, management will continue to rely on the auditors to assist in preparing the City's financial statements and schedule of expenditures of federal awards and assist with certain year-end adjustments. Blyann Johnson Ongoing Finding 2024-002: Internal Control Environment The City is aware of the lack of segregation of duties caused by the limited size of its staff. Segregation is enhanced whenever possible and the council assumes an active role through monthly review of receipt and disbursement transactions and monthly financial statements. Blyann Johnson Ongoing Finding 2024-003: Significant Deficiency - Internal Control Over Procurement, Suspension and Debarment City personnel will make every effort to familiarize themselves with the rules of the Federal Awards programs. Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Blyann Johnson 12/31/25

Significant Deficiency over Procurement Contact Person Responsible for the Corrective Action Plan: William Roberson, Financial Services Director Corrective Action Plan: The County identified a problem during the fiscal year, corrected the issue during the fiscal year, and shared the information with the audit team. Procurement for the new radio read water meters began with informal solicitation of pricing during the prior administration which ended in February 2023. The lack of formal procurement was identified as an issue by the interim county manager and recommended that the County reject the three informal bids. Subsequently, the County initiated a formal procurement process and is documented in meeting minutes, and a copy of County Administration’s memorandum to the Board of Commissioners was shared with the audit staff early in the audit process. The project was approved and contract awarded on July 5, 2024. Anticipated Completion Date: Completed

Special Education Cluster - Procurement, Suspension and Debarment The finding is a material weakness in internal control over federal awards and material compliance finding due to the District not obtaining and/or retaining documentation for an adequate number of price quotes and no retention of documentation related to suspension and debarment of vendors. The District will continue to train staff on the District’s procurement policy and the requirement to retain documentation for procurement decisions, including documentation of suspension and debarment verifications. Responsible official: Janice Boucher, Finance Manager, jboucher@shawanoschools.org Anticipated Completion Date: June 30, 2025

Identifying Number: SA 2024-002 Description of Finding: During the audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, "Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval". During the audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During the audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred were performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Corrective Actions Taken or Planned: We are in the process of updating our Procurement Policy. We will ensure that we follow these updated policies and procedures to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

Federal Award Finding: 2024-002 Material Weakness in Compliance and Internal Control over Procurement and Suspension and Debarment Name and Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH has evaluated the processes and procedures regarding procurement and suspension and debarment, as well as the processes for maintaining records supporting all procurement activity. Management will appoint an individual to oversee this. Proposed Completion Date: June 30, 2025

2024-002 - LACK OF WRITTEN FISCAL POLICIES AND PROCEDURES As of March 27, 2025, scaleLIT has updated its fiscal policies and procedures to reflect all the federal guidelines required by the Uniform Guidance. The scaleLIT Board Treasurer has reviewed and approved the updates.

Identifying Number: 2024-002 – Procurement and Suspension and Debarment Finding: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with its own procurement policy. Corrective Actions Taken or Planned: We agree with the auditors’ findings. It should be noted that 100 percent of FY2024 equipment purchases were audited, consisting of one piece of equipment. Although the current policy for purchases over $25,000 was followed, the findings were not properly documented. In response, a checklist will be developed through the grants management office,compliance training will be conducted with PIs at the time of grant award and compliance will be implemented by the Dean or respective department head. Policies and procedures will be followed and properly documented for all future purchases of equipment to be funded by federal or state dollars. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: April 30, 2025

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We had never been instructed to do price quotes for items purchased from the HPS Purchasing Co-Op before. In the future, we will obtain price quotes when purchasing from HPS when purchases are above the micro-purchasing threshold. Or we will find a different purchasing avenue and will not use HPS. The cafeteria director is currently discussing this with each of the cafeteria supervisors to decide which avenue they will use to avoid the finding in the future. Going forward, for any vendor expected to equal or exceed $25,000 that is paid from school lunch funds (or any federal funds for that matter), someone at the school corporation will verify those vendors aren’t suspended or debarred. Anticipated Completion Date: 08/01/2025: The next school year.