Corrective Action Plans

The College will retain all procurement documentation going forward.

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

Corrective Action Plan Organization: Weingart Center Association Date: July 26, 2024 Weingart Center Association respectfully submits the following corrective action plan (“CAP”) for the year ended April 30, 2022. Name and address of independent public accounting firm: Armanino, LLP 11766 Wilshire Blvd. 9th Floor Los Angeles, CA 90025 Audit period: April 30, 2022 The findings from the April 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal awards SIGNIFICANT DEFICIENCY 2022-007 – Procurement process Auditor Recommendation: Management should revise its documentation system to allow for centralized and accessible storage of support for its vendor procurement process. Action Taken: Management will implement a process to formally document vendor selections. Name of responsible person: Kevin Matthews, Consultant CFO Anticipated completion date: The new policy will be implemented in August 2024.

Panthera will conduct additional training and enhance the expenses review process to ensure newly issued 2023 procurement policy guidelines are being followed.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Stevens County January 1, 2022, through December 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 US. 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 County's internal controls were inadequate for ensuring compliance with federal procurement, suspension and debarment requirements. Name, address, and telephone of County contact person: Jill Jacobs, Chief Deputy Auditor 215 S. Oak St, Colville, WA 99114 509 684-7549 Corrective action the auditee plans to take in response to the finding: 1) The County has drafted and adopted Resolution 85-2023 on July 17, 2023, addressing the federal procurement standards recommendation. 2) A staff member took training on federal procurement standards and processes related to FEMA recovery efforts after a disaster and has shared the documents and training aids with staff that do federal procurement. Further, review with several staff was done related to this training to beef up internal knowledge and controls. 3) The County has trained staff on proper documentation and retention of documentation on suspension and disbarment. Further, the County is currently working on an internal policy on this subject. We expect to have this policy complete and adopted by May 31, 2024. Anticipated date to complete the corrective action: May 31, 2024

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 four (4) vendors - CJAWS, Inc., Edmentum, Inc., Savvas Learning Company, and Technology Resource Advisors, Inc. This is a repeat finding (2021-007) from the previous fiscal year for CJAWS, 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.

The Wilmington Land Bank is working to rectify the deficiency identified in the procurement policy and procurement action documentation finding. The Land Bank has committed to adopting a written procurement policy that will comply with federal requirements in 2 CFR Part 200 Subpart D as well as any local and state requirements. Becky Vogel, the Land Bank’s Director of Finance will create the policy, the Land Bank’s Finance Committee will review the policy, and the Land Bank’s Board of Directors will adopt the policy no later than the August 1, 2024 Board of Directors meeting.

District management concurs with the finding and has implemented an additional procedure to ensure the federal procurement requirements are met. Purchasing will obtain quotes and ensure the federal and not state requirements are met.

Our 2021-22 Audit Report had one finding, related to procurement in the Child NutritionProgram.Here is our corrective action plan (CAP)1. We understand that we did not follow all required procurement policies for the2021-22 school year. This finding was somewhat of a surprise to us, as we had aveteran Director in place. For whatever reason, she either believed theserequirements were not in place due to the pandemic, simply chose to ignore thepolicies, or destroyed the entire audit trail as she left the District. Regardless, wedo accept the finding, since we have no way to remedy it for 2021-22.2. We believe we have already correctly satisfied all of the requirements forprocurement under the Child Nutrition Program for 2022-23. We have alsoreviewed the documentation for 2022-23 with our auditors. We also now havetwo people making sure these policies are followed and the documentation ismaintained. These two people are:a. Steve Barekman, Chief Business Official and Executive Director of Food andNutrition Servicesb. Julie Beer, Director of Food and Nutrition Services

REFERENCE: 2022-018 ? Procurement and Suspension and DebarmentResearch and Development Cluster (12.420, 93.103 and 93.853)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Corrective Action Plan: Training was provided to program and operations managers to add additional documentation to requisitions. An updated work instruction will be developed by the research administration department outlining the necessary documentation for non-competitive purchases.Person Responsible: Sheri Sanders, Division Director Research AdministrationExpected Completion: April 2023

FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Service Program, COVID-19 ?Summer Food Service ProgramALN Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Chad Yencer - SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:BCS has established the following internal controls to ensure compliance:1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, thesuperintendent will require that any vendors selected are in compliance with theProcurement and Suspension and Debarment compliance requirement by completing one ofthe following quality checks with each vendor prior to purchase:a. Checking the federal System for Award Management (SAM) database athttps://sam.gov/content/exclusions and maintain a screenshot of the search results.b. Collect a certification from the vendor directlyc. Add a clause or condition to the covered transaction with the vendorAnticipated Completion Date:This corrective action will be implemented and completed immediately with any purchase made that meets theabove threshold.

Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retainedfor audit purposes.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding This finding was a result of only one vendor being availableat the time. The Office of Purchasing and Grants staff will comply with the requirement forobtaining quotes and document any exceptions if two quotes cannot obtained.Name(s) of the contact person(s) responsible for corrective action: BCPS Office ofPurchasing staff, grant accountants/fiscal staff.Planned completion date for corrective action plan: For immediate implementation andongoing.

Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: The College will implement training and procedural changes during the grant budgeting process and in the post-award process to ensure documentation of reasonable prices and rates to include training related to handling vendors who may be used across multiple funding sources.Name of the contact person responsible for corrective action: Tess Powers, Director of Faculty Research Support (719) 389-6318Planned completion date for corrective action plan: May 1, 2023

FINDING 2022-001Contact Person Responsible for Corrective Action: Mayor Terry AmickContact Phone Number: 812-752-3169Views of Responsible Official: I concur with the findings.Description of Corrective Action Plan: The City plans to review existing policies and procedures andmake any needed changes to endure that they are in compliance with the federal compliancerequirements for procurement as well as suspension and debarment. Furthermore, controls will beestablished to ensure that the City?s policies related to compliance with the federal compliancerequirements for procurement as well as suspension and debarment are followed.Anticipated Completion Date: December 31, 2023

2) Finding 2022-03 - The School failed to obtain price quotations from multiple sources for a purchase that exceeded $10,000. a. 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. b. Implementation date - Anticipated completion June 30, 2024. c. Persons responsible for the implementation - The Board of Directors and Head of School.

Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementation of the current procurement policy, all staff members have been trained on the procurement policy, and the Finance and Operation teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with 2 CFR 200. With the policy in place, we recognize that implementation across teams is critical and are actively training people managers to improve oversight and improve implementation. Anticipated Completion Date: January 31, 2024 Responsible Official: Associate Director, Grants Management and Compliance; Director of Program Operations

Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.

U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-008: Procurement – Material Weakness Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement is adequately documented so that goods and services are purchased in accordance with Uniform Guidance and other federal guidelines. Grantee Response and Corrective Action Plan 2022-008: We acknowledge the gap identified between our policy framework and its execution, particularly in the area of maintaining supporting documentation. The Center for Black Women’s Wellness has approved policies that are designed to meet the requirements of the Uniform Guidance; however, we recognize that in practice, implementation has been inconsistent. Notably, of the sixty transactions reviewed, eight were found lacking in supporting documentation. To address this issue, we have already taken corrective measures by reinforcing our procedures and ensuring that appropriate staff are aware of these requirements. In 2024, we strengthened our oversight by engaging a Contractual CFO who will be instrumental in implementing these enhanced controls. This effort is part of our ongoing commitment to ensure full compliance and transparency in our procurement processes, thereby aligning our practices more closely with our established policies. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

Material Weakness in Internal Control over Compliance Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they arenot suspended or debarred. These procedures should include documenting the date that suspension and debarment verifications are made. In addition, we recommend The Organization formally adopt a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. There is no disagreement with the audit finding. Action taken in response to finding: Since Fall/Winter 2023, we have reviewed the Organization’s controls for procurement, suspension, and debarment, including the process for reviewing potential contractors for suspension and debarment. We have expanded our controls and increased training to improve control strength, and we have formally adopted a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 04/01/2024

Action Taken: Range Mental Health Center, Inc. and Subsidiaries will adopt a documented procurement policy consistent with the standards of 2 CRF section 200.317 through 200.320 to use procurement of the acquisition of property or service required under federal awards or sub-awards.

1. The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of suspension and debarment for all potential contract service providers. The Center notes that one of the contracts selected for testing arose during an emergency situation (flooding). 2. CFO will ensure that all invoices and supporting documentation are retained. ED and/or Director of Legal Services (depending on amount of expenditure, both may be required) will approve electronic payments in Bill.com. Approval of expenses paid with paper checks will be indicated by signature of checks after reviewing accompanying support.

Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followeed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures will help ensure compliance ith Compilance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: there is no disagreement with the audit finding. Action taken in response to finding: The Organization will develop a written procurement policy and will develop controls to monitor when expenses approach the various procurement thresholds to help us complete the appropriate procurement procedures in compliance with out policy. Name(s) of the contact person(s) responsible for corrective action: Frank Caruso, Director of Finance and Operations. Planned completion date for corrective action plan: Sarted in January 2024. If the the U.S. Department of the Treasury has questions regarding this plan, please call Frank Caruso, Director of Finance and Operations at (602) 241-4645.

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles 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: 2022) Questioned Costs: $21,440.00 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 Plan: The Harris County SNP will review internal controls and apply correct procedures to all purchases made. Estimated Completion Date: June 30, 2024 Contact Person: Meghan L. Ceja Telephone: 706-628-4206 Email: ceja-m@harris.k12.ga.us

FA 2022-002 Strengthen Controls over Procurement 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 AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 225GA324N1199 (Year: 2022) Questioned Costs: None Identified 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 Hancock County School District has implemented the bid process to ensure that the School District’s procurement procedures are followed. Estimated Completion Date: June 30, 2024 Contact Person: Matthias Jones, Finance Director Telephone: (706) 444-5775 Ext. 125 Email: mjones@hancock.k12.ga.us