Corrective Action Plans

2023-002 U.S. Department of Environment Protection – Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures – Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: The water systems improvements federally funded project is the Authority’s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority has been working over the past year to draft and develop these policies and procedures as they relate to federal programs, and to get them documented in writing. The Authority is currently working with their attorney to have the written polices established and plan to have this completed within the next fiscal year. Once the required policies are written, the Board of the Authority will review the policies, revise as appropriate, and adopt the policies for the Authority to comply with the federal funding requirements.

Finding 2023-001 – Internal control deficiency and noncompliance over Procurement 1) Communication & Awareness: • Debrief by Director, Research and Sponsored Awards with the Community Health Department Senior Leaders and Program Managers regarding the audit finding; including procurement requirements, the nature of the deficiency and failure points. This occurred on 8/27/2024. • Meeting between Director, Research and Sponsored Awards, PHS Communications and Brand Management leadership and VP of Community Health to communicate procurement requirements and clarify responsibilities for communication of applicability of Federal procurement requirements to specific projects for which advertising services are requested. Initial Meeting occurred 8/28/2024. 2) Training & Education: • Targeted Training with the Community Health department (primary recipient of on-going Federal funding) on Federal procurement requirements. This training will be provided by the Research and Sponsored Awards staff and will be extended to any additional departments new to Federal funding. • Enhancement of existing required annual enterprise-wide leadership training that includes a section on grant funding with increased emphasis on procurement. Research and Sponsored Awards department is responsible for content. • Development of materials for new hires or others new to grant funding who are responsible for federally funded projects (collaboration between Research and Sponsored Awards department and Community Health department) 3) Policies & Procedures: • Written Procedures & Toolkits: Development of written procedures for contracting, exclusion checks and general procurement of goods or services to include checklists / toolkits to facilitate actions required for compliance with Federal procurement rules. • Update to existing policy “Federally funded Grants or Contracts – Procurement / Purchase of Supplies, Services and Other Property” to clarify the responsibilities for communication of applicability of Federal procurement requirements when a department receiving Federal funding procures goods or services through other PHS departments. 4) Collaboration with PHS Marketing department to ensure pathways exist for competitive bids, when necessary, including documentation of processes related to procurements under Federal funding. The first meeting was held 9/12/2024. 5) The Director, Research and Sponsored Awards and Community Health Department will review the items identified as questioned costs to identify if any improper payments were made to PHS. Contact Person: Lori Galves, Director, Research and Sponsored Awards Anticipated Completion Date: December 31, 2024

Finding 2023-002 – Inadequate Design of Monitoring Controls over Procurement Policies Although Hamakua Health staff were not able to provide all the procurement records required by the auditors in the short period of time that was given, these procurement documents should have been scanned by those who initiated and completed the procurement processes and kept them in a ShareFile for easier access, especially for those contracts that are still active. This is now the new standard practice for all new procurement processes. Procurement policies that are complete, correct, and compliant exist have been and are in use at the Health Center. A process has been implemented where a daily purchases receipts log is kept, Purchase Orders and Packing Slips are scanned and attached to invoices to process for payment. Corrective actions have already been implemented at this time. Responsible person to be contacted regarding management responses: John R. White, MHA, BA, CHW Chief Executive Officer jwhite@hamakua-health.org 808.930.2745

Views of Responsible Officials: The Center will update its procurement policies and ensure staff are trained on all procedures and requires documentation. Name and Title of Responsible Official(s): Vibha Bhatia, Vice President of Finance and Operations Anticipated Completion Date: September 30, 2024

Texas Biomed has detailed procurement policies in place that outline requirements relative to expenditures on federal awards. Historically, training of new employees in Purchasing and employees in other departments with purchasing-related responsibilities was provided periodically. Turnover in 2023 affecting the Purchasing department led to a failure to ensure adequate training was provided such that compliance responsibilities were clearly understood. With the implementation of a new P2P system in Q3 2024, training has been updated for the new system and will incorporate reminders of compliance requirements for federal awards. Separate trainings are planned for September 2024 for Purchasing staff and for staff in other departments involved in the purchasing process. Training will include requirements to obtain and document multiple quotes for purchases over $10,000 and to document sole source justification when there are no other viable suppliers for a purchase. Purchasing staff will review requisitions to ensure the appropriate documentation is saved with the Purchase Order in the purchasing system. Any new employees or temporary workers in the Purchasing department will be trained on the requirements before they are allowed to begin processing purchase requisitions. Responsible Parties: Eva Zepeda, Director, Finance; Patricia Thompson, Assistant Director, Materials Management Completion Date: September 30, 2024

Seymour Public Schools will go out to bid for any purchases over $25,000. Jason Vieira of the Towns Finance Department is responsible for the corrective action plan.

FINDING 2023-002 Finding Subject: Water and Wastewater Disposal Systems for Rural Communities – Procurement Summary of Finding: One vendor was not procured according to the simplified acquisition threshold. Contact Person Responsible for Corrective Action: Tammy Selby Contact Phone Number and Email Address: 812-354-8511 tselby@petersburg.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, we will bid out all professional services. We will follow our same policies for bidding out to other vendors. Anticipated Completion Date: December 31, 2024

Finding 2023-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Findings: The County did not have a Board approved procurement policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. The County had five vendors that qualified for testing under small purchase procurement requirements (vendors paid $10,000-$150,000). Of the two chosen for testing, one was awarded a contract without the County obtaining quotes. The contract awarded was $31,000 for engineering services related to drain construction. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process was not clear to the Auditor’s Office or the departments submitting the claims for payment. We are more aware of the correct process and procedures that need to take place and will add those procedures to our Internal Control policy to ensure that the vendor is not suspended or debarred. Anticipated Completion Date: October 2024

US Department of Treasury Coronavirus State and Local Recovery Funds Assistance Listing No. 21.027 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the Town implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Appropriate management personnel will review procurement procedures to ensure that all expenditures of federal funds is in compliance with 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award. Name(s) of the contact person(s) responsible for corrective action: John Townsend, Deputy Town Administrator and Director of Finance. Planned completion date for corrective action plan: October 1, 2024

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 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 expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

Coronavirus Relief Funds – Assistance Listing No. 21.027 Recommendation: CLA recommends the County review procurement policies for the entire County 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: Iron County will review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Name of the contact person responsible for corrective action: Christan Brandt, County Clerk Planned completion date for corrective action plan: December 31, 2024

FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: 1. For Purchases Under $50,000 a. Purchases or Contracts of $1,000 or Less i. Shall be reviewed and approved by the designated Purchasing Agent. ii. The Department Head, Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. b. Purchases or Contract between $1,000 and $10,000 i. Shall be reviewed and approved via a Requisition Form by the Purchasing Agent/Department Head. ii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. c. Purchases or Contracts between $10,000 and $50,000 i. Shall be reviewed and approved via a Requisition Form by the Department Head, Procurement Manager and Town Manager. ii. Should have (3) formal quotes from different vendors. iii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iv. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. v. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. d. Purchases of at Least $50,000 and Less Than $150,000 i. Shall be reviewed and approved by the Department Head, Procurement Manager, Town Manager and Town Council. ii. The information shall be presented to Town Council and should contain (3) formal quotes from different vendors. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. e. Purchases of $150,000 or More i. Shall be submitted via a formal bidding process. ii. Shall be reviewed by Department Heads, Procurement Manager, Town Manager and Town Council. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. 2. To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Anticipated Completion Date: Policy change 2023. Purchase order change 8/31/2024.

Current plan & Actions being taken and developed. 1. Develop and Update Procurement Policies Create Comprehensive Policies: Ensure that the procurement policy covers all aspects of the procurement process, including vendor selection, bidding, contract management, and expenditure approvals. Regular Reviews: Periodically review and update the policies to reflect changes in laws, regulations, or best practices. 2. Establish Clear Procedures Document Procedures: Develop detailed procedures for each step of the procurement process, from requisition to payment. Create a procurement checklist. Standardize Processes: Ensure consistency across departments by standardizing procedures for procurement activities. Provide each department with the procurement check list. 3. Training and Awareness Conduct Training: Provide regular training for all staff involved in procurement to ensure they understand the policies and procedures. Promote Awareness: Increase awareness about the importance of compliance with procurement policies. 4. Implement Controls and Checks Segregation of Duties: Divide procurement responsibilities among different staff to reduce the risk of errors or fraud. Approval Processes: Establish clear approval hierarchies and limits for procurement activities and expenditures. Audit Trails: Maintain detailed records and documentation for all procurement transactions. 5. Monitor and Review Compliance Regular Audits: Conduct regular internal and external audits of procurement activities to ensure adherence to policies. Performance Metrics: Develop metrics to evaluate the effectiveness of procurement processes and identify areas for improvement. 6. Enforce Accountability Responsibility Assignments: Assign clear responsibilities for monitoring and enforcing procurement policies. 7. Utilize Technology Data Analysis: Use data analytics to track spending patterns, vendor performance, and policy compliance. 8. Encourage Transparency Open Bidding Processes: Ensure that procurement opportunities are advertised openly and fairly. 9. Feedback and Continuous Improvement Solicit Feedback: Gather feedback from staff and vendors on the procurement process to identify areas for improvement. Continuous Improvement: Regularly update procedures and policies based on feedback and audit findings. 10. Departmental Integration Cross-Department Coordination: Ensure that all departments are aligned with procurement policies and procedures. Provide each department with the procurement check list. Name(s) of the contact person(s) responsible for corrective action: All Department Directors, in conjunction with the Finance Department, are collectively accountable for the implementation and oversight of this corrective action plan. Requests for Proposals (RFPs) will be reviewed and approved in an open Town Meeting, with decisions made by the Mayor and Commissioners. Planned completion date for corrective action plan: Implementation commenced around June 1, 2024 and is projected to be fully operational within a year June 1, 2025.

The System will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with §200.320. Additionally, the System will enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. The system will implement a review of all contracts to ensure the appropriate language exists regarding suspension and debarment regulations and/or consider an annual review of SAM.gov for all vendors. Interim CFO, Sunnie Hines Timeline 180 days

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 vendors –– Houghton Mifflin-Harcourt ($509,919), Beaver Valley Intermediate Unit ($419,826), and Smart Solutions ($449,303). 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 2023-2024 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: Saving Ourselves ($30,000), AGI Repair ($16,216), IXL ($19,218), Learning Systems Associates LLC ($25,425), AGC Education Inc. ($11,644), Apple ($163,505), Germ Solutions LLC ($160,070), Graham Security ($12,025), Curriculum Designers, Inc. ($27,875), RJ Rhodes Transit, Inc. ($24,845). 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.

Inadequate Records Retention Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for 1 of the 5 projects selected. In conjunction with our FY2023 audit, please see the City’s corrective action plan below: Management Response: The Finance Director is initiating conversations with department heads regarding updating procurement policies and procedures. We are taking steps to ensure all procurement documents are stored centrally in order for these items to be readily available moving forward. Expected completion date: In regards to procurement documents corrective action has already been taken for FY 23-24; regarding updating procurement policies and procedures expected completion date 6.30.25. Party Responsible: Jennifer Watts, Finance Director Contact Information: jwatts@miamiokla.net

2023-003: Procurement Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should 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: Implemented in February 2024.

The City will work internally within the City Manager’s office and Finance Department to adopt a centralized procurement process and policy that is in line with Uniform Guidance. Staff identified to participate in the process will be trained as necessary.

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 three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, 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.

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 ‘Associates in Counseling’. 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 for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will 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. The District’s timeframe for implementation is effective immediately.

Water and Waste Disposal Systems for Rural Communities – Assistance Listing No. 10.760 Recommendation: City personnel should familiarize themselves with the documentation requirements required by the CFR related to procurement. In addition, City policies and procedures should be modified to ensure documentation is maintained on the justification for any noncompetitive procurement transactions that are entered into and that the justification is reviewed and approved by someone other than the one making that determination. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We are reviewing and updating our internal controls and written policies to address this item with our employees. Employees will receive training on the updated polices. Name(s) of the contact person(s) responsible for corrective action: Michele Pogodzinski, clerk/treasurer Planned completion date for corrective action plan: 12/31/2024

Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.

3) Finding 2023-003 - The School failed to obtain price quotations from multiple sources for purchases that exceeded $10,000. Implementation of plan of action - Management will review its procurement policies to ensure that the School complies with 2 CFR 200.320 of the Uniform Guidance. Implementation date - Anticipated completion July 30, 2024. Persons responsible for the implementation - The Board of Directors and CEO.

We increased our accounting capacity in late August 2023, and that staff member is now trained up. We have also contracted with an outside consultant to see if we can streamline some of our processes and to see if we need additional capacity or a reallocation of tasks within the finance team. We have also may stressed our procurement policies during the current year and our Director of Operations has worked with the finance team and staff to better follow the policy during the year. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: David Maloney, Shelter House Controller