Corrective Action Plans

CONTACT PERSON: Terri Smith, Assistant Superintendent of Business Services, trsmith@rhmail.org CORRECTIVE ACTION: The District will ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. PROPOSED COMPLETION DATE: Prior to June 30, 2025

CONTACT PERSON: Matt Owens, Chief Financial Officer, mattowens@pickens.k12.sc.us CORRECTIVE ACTION: The District will ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. PROPOSED COMPLETION DATE: Prior to June 30, 2025

Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025

Views of Responsible Officials: MCCC and Affiliate used the vendor historically and previously got an approval. They are currently in contact with their GOTR to get the approval in writing for the current grant period.

The Purchasing department will develop and maintain written procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micro purchase threshold require multiple quotes and that these quotes are properly documented as evidence. “Small purchases” are those where the total dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. Purchasing department staff will be trained on this procedure and the District will adopt a board policy to address this procedure. The contact person is Philippa Townsend and the anticipated completion date is 11-1-2025.

Procurement Federal Program Title: Research & Development Cluster Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for obtaining competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Accounting and Purchasing will both review requisitions within Jaggaer to make sure appropriate bids, and or exemptions are documented or attached. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024

Board policy will be followed to ensure purchases are in compliance with all federal and state regulations.

Finding: 2024-001 – Procurement, Suspension and Debarment U.S. Department of Education – Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education (MDE); All project numbers. Auditor Description of Condition and Effect: Of the six vendors tested for compliance with procurement requirements, the District was unable to provide documentation for compliance with procurement standards for one vendor tested. The vendor had total expenditures of $81,757 during the current fiscal year. Included in these expenditures was the purchase of equipment in the amount of $30,321 which is in excess of the MDE competitive bid threshold. The District was unable to provide documentation to support that competitive bidding was performed in accordance with the District's policies and procedures and MDE guidelines. Additionally, multiple quotes were not obtained for the remaining purchases not in excess of the MDE competitive bid threshold. The District could not properly document compliance with federal requirements as required under Uniform Guidance. Auditor Recommendation: We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. Corrective Action: District officials will review the District's internal procedures to ensure future compliance with and appropriate documentation of procurement requirements vendor relationships. Responsible Person: Lauren Bailey, LEA Business Manager Anticipated Completion Date: June 30, 2025

Recommendation: The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Corrective Action Plan: The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.

Recommendation: The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Corrective Action Plan: The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.

Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance. Action Taken: Hubbs-SeaWorld Research Institute plans to modify its procurement procedures for federal grants to comply with 2CFR section 200.319 by continuing to require at least three bids (or a sole source statement, if applicable) for any purchases over the micro-purchase threshold, currently $10,000. In addition, we will monitor cumulative vendor purchases on a monthly basis to ensure that price or rate quotations are obtained from an adequate number of qualified sources, that is, at least three bids (or a sole source statement, if applicable.)

Auditor Description of Condition and Effect: Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Auditor Recommendation: We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. Corrective Action: The District identified the omitted prior year capital asset additions and has reconciled their UAAL expenditures and benefits accruals to agree with the required audit adjustments. The District will work to ensure the proper year end reconciliations are put into place to avoid future reporting errors. Responsible Person: Chad Baas, Business Manager. Anticipated Completion Date: June 30, 2025.

Management’s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance/ShelterCare 2. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 3. The anticipated completion date: a. New processes will be implemented by 11/1/2024.

2024-006 Procurement Corrective action planned: OMC’s Purchasing Policy will be updated to ensure compliance with federal regulations. Documentation will be reviewed by accounting staff. Anticipated completion date: 11-30-2024 Contact person responsible for corrective action: Cathy Liles, Director of Fiscal Operations

Corrective Action Plan Finding No.: 2024 - 001 Condition: The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines. Plan: The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Scott Fisher, Superintendent

The department will adopt written policies with the Uniform Guidance for Federally Funded Grant Programs accepted by the department.

FA 2023-001 Improve/Strengthen Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Year Finding: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.371C - Comprehensive Literacy Development S371C190016-19A (Years: 2017-21) $124,399.84 FA 2022-002 Description: A review of expenditures and journal entries charged to the Comprehensive Literacy Development program revealed that the School District's internal control procedures were not operating to ensure that appropriate reviews and approvals occurred and the School District's procurement procedures were followed. Corrective Action Plans: The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Dr. Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

Corrective Actions Planned To address the deficiency in internal controls over compliance with respect to procurement, CHC will implement the following corrective actions: CHC will develop and implement a written procurement policy that conforms to the Uniform Guidance.; CHC will ensure sta􀀁 receive adequate training on the procurement policy and the required methods of procurement to be made when making procurements with federal awards. Responsible Person(s): CHC President, Rob Dibble as Primary; CHC Vice President Betsy Gordon as Backup Corrective Action Plan Dates: Schedule implementation starts: February 1, 2026; Staff training starts: March 1, 2026; Review process in effect starts: April 1, 2026

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

Personnel Responsible for Corrective Action: Eljana Kaziaj, Controller Anticipated Completion Date: ASAP. Goal Date is August 31, 2025 Corrective Action Plan: Management accepts the recommendation. It will modify and strengthen our policy and procedure regarding the procurement process to reflect the alignment with federal regulations. Will also maintain a suspension and debarment on vendors. The list will be reviewed monthly.

Management acknowledges this finding, which occurred during a period of rapid program expansion when procurement infrastructure had not yet been fully developed. Since the audit period, we have completely overhauled our procurement process to ensure full compliance with the Federal procurement standards. We have implemented a formal procurement policy, created a dedicated Procurement sub-department within Finance, hired a Procurement Supervisor and support team, and launched a new procurement software platform to ensure proper solicitation, documentation, approval routing, and record retention for all Federally funded programs. These upgrades establish consistent competitive bidding, justification procedures, conflict-of-interest safeguards, and transparent procurement. In addition, we have strengthened oversight, provided staff training on Federal procurement standards, and embedded monitoring practices to ensure ongoing compliance. Management is confident these substantial structural improvements have significantly reduced the risk of noncompliance and positioned the organization for full alignment with federal procurement standards going forward.

2023-002 Compliance and Internal Controls over Procurement (Material Weakness and Noncompliance) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to procurement are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Corrective Action: In alignment with the recent leadership transition, a comprehensive policy and procedure manual has been established to ensure our procurement practices meet HUD guidelines. The following outlines our updated procurement policy: 1. Compliance with Standards: All procurement of property (goods, supplies, or equipment) and services must adhere to the standards of conduct and conflict-of-interest requirements outlined in 2 CFR 200.317 and 200.318. 2. Micro Purchases (Under $9,999): Temenos CDC (TCDC) will document the reasonableness of costs for all micro purchases to ensure appropriate spending practices. 3. Small Purchases ($10,000 and above): For small purchases exceeding $10,000, TCDC will solicit a minimum of three bids for services to promote competitive pricing. 4. Vendor Vetting: 1. All new vendors will be vetted through the SAM (System for Award Management) Department prior to the initiation of services. 2. Continuous service providers will be subject to an annual vetting process to ensure ongoing compliance and quality. These measures are designed to reinforce our commitment to transparency, accountability, and compliance with HUD requirements. Responsible Parties: Sandra Robicheaux - Executive Director Madelyn Wages – Director of Supportive Services Ramona Edwards – Property Manager Date to be Corrected: Implementation for above changes went into effect 6/01/2024

Response to finding 2023-002 – Procurement, Suspension, and Debarment Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-002. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization operated with significantly reduced staffing and limited capacity, which delayed the development of procurement policies addressing suspension and debarment requirements. Initial governance updates occurred during the 2025 Q4 Board meeting, where the Board approved a revised version of the By-Laws focused on correcting deficiencies in board structure and conflict-of-interest provisions. Procurement procedures recommended in this finding were not included in that initial revision but are scheduled for development and implementation as part of the 2026 rebuilding phase. Corrective Action taken in 2025: While no procurement-specific corrective action has yet been implemented, foundational updates to the By-Laws were approved at the 2025 Q4 Board meeting to address structural governance issues. These updates establish the basis for incorporating required procurement, suspension, and debarment procedures. The Operations Manager and Advisory Consultant have begun drafting updated procurement policies to ensure compliance with federal requirements. Corrective Action Planned for 2026: Draft procurement, suspension, and debarment policies will be completed and presented to the Board as a formal resolution in early 2026. Upon approval, these policies will be incorporated into the By-Laws and will take immediate effect. The Board has also approved the planned hiring of a consultant with Executive Director and strategy experience in 2026 to support policy implementation, training, staff alignment, and ongoing compliance review. These measures will ensure full compliance with procurement requirements throughout the 2026 operating year and beyond.

Finding 2023-003: Test no 15 is for Department of Education and the rest are for Department of Health. • For test no. 15, obligation 361854 – Of 3 quotations obtained for a small purchase transaction, the highest quotation was selected, there was no documented justification to support the procurement selection. • For test no. 16, obligation 372216 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 17, obligation 372215 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 22, obligation 334914 – The procurement file included 2 quotations and a justification form that did not relate to the transaction as it cites an explanation for purchasing goods from other vendors unrelated to the actual transaction. Of the 2 vendors included, there did not appear to be a notable difference in goods/services offered, however the higher of the 2 was selected. Consequently, we could not determine the ultimate basis for vendor selection. • For test no. 30, obligation 358537 – The procurement as sourced from one vendor and lacks additional quotations. There was no documented justification for the sole-source procurement. Root Cause Analysis Ineffective documentation filing and retention controls, further impacted by the relocation of the State Treasury office. Corrective Actions • Strengthen procurement documentation controls and ensure rationales and justifications for vendor selection are retained in procurement files. Responsible Parties Director of Education and its administrative officers Director of Health and administrative officers Director of DOTA, certification and payable section Timeline Verification of Effectiveness Periodically verify the department's purchases to ensure that no instances of noncompliance are still taking place.

Finding 2023-003: Test no 15 is for Department of Education and the rest are for Department of Health. • For test no. 15, obligation 361854 – Of 3 quotations obtained for a small purchase transaction, the highest quotation was selected, there was no documented justification to support the procurement selection. • For test no. 16, obligation 372216 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 17, obligation 372215 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 22, obligation 334914 – The procurement file included 2 quotations and a justification form that did not relate to the transaction as it cites an explanation for purchasing goods from other vendors unrelated to the actual transaction. Of the 2 vendors included, there did not appear to be a notable difference in goods/services offered, however the higher of the 2 was selected. Consequently, we could not determine the ultimate basis for vendor selection. • For test no. 30, obligation 358537 – The procurement as sourced from one vendor and lacks additional quotations. There was no documented justification for the sole-source procurement. Root Cause Analysis Ineffective documentation filing and retention controls, further impacted by the relocation of the State Treasury office. Corrective Actions • Strengthen procurement documentation controls and ensure rationales and justifications for vendor selection are retained in procurement files. Responsible Parties Director of Education and its administrative officers Director of Health and administrative officers Director of DOTA, certification and payable section Timeline Verification of Effectiveness Periodically verify the department's purchases to ensure that no instances of noncompliance are still taking place.