Corrective Action Plans

We will revise our policies and procedures on purchases with federal awards so that we will meet these newly required federal procurement regulations. We will start including Appendix II to Part II Summary where applicable in future contracts.

Condition: We identified 4 expenditures, during testing, that the City did not verify were in accordance with their internal procurement policy, pursuant to 2 CFR 200.319 and 200.320 prior to entering into contracts with award funds. Planned Corrective Action: Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City of Port Huron management and staff will continue to improve communication with and between departments to ensure all staff understands the purchasing policy. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

The Business Department will review the Uniform Guidance requirements with all grant administrators and procurement staff to ensure compliance with federal regulations and district policy; and it will establish a more thorough review process for contracts to ensure compliance with all requirements.

Finding: 2023-002 – Procurement, Suspension, and Debarment – Contract Bidding Auditor Description of Condition and Effect. The District did not obtain price or rate quotations for the purchase of services for one vendor that met the small purchase threshold. As a result of this condition, the District paid a vendor with federal funding that was not procured in accordance with federal regulations. Auditor Recommendation. We recommend that the District update its procedures to ensure that all services are appropriately procured in accordance with federal and state requirements. Corrective Action. Management concurs with finding. The District will only allocate costs to the food service program that have been properly bid out and obtain quotes for all services in excess of the Federal micropurchase threshold. Responsible Person: Emili Jones, Director of Business and Finance Anticipated Completion Date: November 1, 2023

Contact Person – Lora Papacheck, CEO Planned Corrective Action – Entity management will review a list of vendors and update documentation in accordance with Procurement standards. Completion Date – Fiscal year 2024

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Rouba Anka, Chief Financial Officer Planned Completion Date: Immediately

District will review procurement policies and provide additional training and education to ensure the minimum requirements of 2 CFR 200 and the procurement policies established are being followed.

There is no disagreement with the finding. Management has updated their district policy and continues to work with staff members to ensure proper execution of purchases.

The District updated the District’s policy and is in the process of providing training to those affected.

Landesa will revise it’s Procurement Policy to meet the standards of the United States Federal Government and all components of 2 CFR Section 200.320. Landesa will revise the Procurement Policy to include clear thresholds for small purchases and simplified acquisitions and clearly address the topics of sealed bids, price analysis, and acquisition costs. Landesa will revise existing procurement forms, such as the third-party due diligence form, to ensure compliance with the revised policy. Landesa will provide training to all relevant staff on the revisions to the Procurement Policy by March 2024. The Director of Program Effectiveness will monitor staff implementation of the revised policy and procedures to ensure compliance with revised policy. Contact person: Director of Program Effectiveness and Anticipated completion date: March 2024

Finding, #2023-001 and #2023-002· Material Weakness - Other Matters, Government Auditing Standards; Major Federal Award Finding - Procurement and Suspension and Debarment Corrective Action Plan: We recognize the carry over nature of these findings in that the contract with the vendor that triggered the finding began in fiscal year 2022 and the work was not completed until fiscal year 2023. Revise the current procurement policy to include federal regulations 2 CFR Section 200.317-200-326 per the thresholds in CFR 200.320. The revised policy will be reviewed with managers responsible for procurement that could potentially exceed these thresholds. Our procurement procedure will be revised to clearly specify the requirements for Small Purchase Procedures for purchases between the micro-purchase threshold and the simplified acquisition threshold per federal government regulations.

Dover Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2023-001 – Procurement Federal Agency: Department of Education Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: COVID-19 – Education Stabilization Fund – 84.425 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Miranda Weaver, Chief Financial & Operations Officer

Finding number: 2023-003; Finding: While testing the procurement requirement, we were able to test compensating controls, but noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: UW Health will develop processes and procedures to ensure compliance with the Uniform Guidance. Vendors will be reevaluated for compliance with the Uniform Guidance prior to being charged to any grant. Anticipated completion Date: June 2024; UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services, and Sara Schiek, Manager of Procurement Services

Management agrees with the findings presented by the auditors. Management has taken the following actions already to meet this standard. The Organization has taken corrective actions to meet this standard for FY24. These actions include the drafting of a procurement policy that aligns with the requirements outlined in 2 CFR 200.320 and communicating the policy to its staff for use when planning to allocate procurement costs to federal grants. Management plans to leverage the existing system in place to track and document compliance with the standard procurement procedures as outlined in the policy. Management is committed to conducting periodic internal reviews as part of our compliance checks. We are dedicated to maintaining strong internal controls over compliance, and these measures will help us meet the standards for procurement used in the acquisition of property or services required under Federal awards.

Condition: The District did not follow the small purchase method for procurement that is required for purchases made between $10,000 and $250,000. This method requires that price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b). Recommendation: We recommend that care is taken to ensure that all the procurement requirements are followed based on the amount of the purchase being made with the federal funds. Management Response: We will follow the procurement standard when not in urgent situations for the product or service we are seeking. Anticipated Date of Completion: June 30, 2024

219 Health Network will develop a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.

The city will implement procedures to ensure preparation of the SEFA and retention of all required federal grants documentation , including ARPA reporting.

The District concurs with the finding. At the time the purchases were made, the District did not realize the federal funds provided required compliance with uniform guidance procurement rules. Therefore, the applicable Uniform Guidance procurement requirements were not applied. To correct this issue, management will update and formalize procurement policies and procedures to ensure potential federal funding sources are identified before or during the purchasing process and that purchases charged to federal awards comply with 2 CFR 200.318 through 200.320. The District will implement procedures to ensure the appropriate procurement method is used, competition requirements are met, cost or price analysis is performed when required, complete procurement documentation is retained, and compliance is reviewed for applicable transactions.

Recommendations: Management should strengthen procurement controls to ensure all purchases follow 2 CFR §§200.318–200.320 and the operating contract. This includes documenting all bids, retaining procurement files, and obtaining required approvals prior to purchase. Views of responsible officials and planned corrective actions: Management agrees with the findings and will ensure all purchasing requirements are met as outlined in the operating contract, West Virginia State Code, and federal regulations and documented in applicable policies and procedures. Training on proper purchasing requirements is anticipated through the West Virginia Transit Authority. Anticipated Completion Date: May 1, 2024

U.S Department of Health and Human Services 2022-002 - Procurement - Assistance Listing No. 93.243 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/services and then utilizing an approved vendors list. Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. Action take in response to finding: Management will ensure the Organization follows the Procurement policy for any future acquistions over the threshold of $15,000 enumerated in the policy and obtain bids and document the selection process. Name(s) of the contact person(s) responsible for corrective action: Manuel Burrola, Accountant Planned completion date for corrective action plan: May 2026

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

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.

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.

Management agrees with the finding presented by the audit. Management has taken corrective actions to meet this standard. The Organization has taken corrective actions to meet this standard for FY23. These actions include the Organization's implementation of a procurement policy with multiple levels of review. All purchases greater than or equal to $30,000 must receive three separate bids from outside vendors. Once the bids are received, the Executive Director will review and present the bids to the Board. The Board will approve the bid that is the most favorable purchase option for the Organization. The finance department will retain all bids received. Additionally, all purchases less than $30,000 that are consistent with the budgeted expenses for the year may require review and signature approval at the discretion of the Executive Director. Employees at the Director level have purchasing authority up to $5,000 and are authorized credit card holders. Employees who are below the Director level and are authorized card holders have purchasing authority up to $1,000. Any purchases greater than the $1,000 limit are required to have approval by their immediate supervisor before the purchase can be made. Once a purchase is made, regardless of the dollar amount, the procurement form must be submitted, with the respective receipt or invoice, to the finance department for processing.

Corrective Action: Snohomish County Food Bank Coalition will develop and implement a formal procurement policy in alignment with the requirements of the Uniform Guidance. Anticipated Completion Date: December 31, 2025