Corrective Action Plans

Procurement and Suspension and Debarment: The College agrees with the finding and takes note of the previous corrective actions that did not fully resolve the issue. The College will update its Purchasing and Accounts Payable Policy to require SAM.gov verification prior to awarding contracts. The College will conduct mandatory procurement training to strengthen compliance with federal requirements.

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, verification of suspension and debarment status, and equitable distribution of micro- purchases. In addition, newly hired staff dedicated to Procurement and Accounts Payable have been onboarded to improve oversight and compliance. With these new systems, strengthened controls, and added staffing capacity, the College is now better positioned to maintain full compliance. Staff have been trained—and will continue to be trained twice a year—on procurement requirements and federal regulations to prevent recurrence of similar issues in future audits.

The Council will insure that all future procurements correctly use and retain a procurement sheet which documents the item purchased, the bids received, as well as the analysis of the reasons for the winning bid. The winning contractor/vendor will be searched on the SAM website to determine that they are not suspended/debarred.

We concur with reservations. While policy requires grantees to distribute micro-purchases equitably among qualified suppliers, during the reporting period it was necessary to secure supplies from any available and reliable source to meet urgent operational needs. This occurred during the pandemic, when Palau experienced significant supply chain disruptions, including delayed shipments and stock unavailability from most vendors. Consequently, micro-purchase awards were concentrated among a smaller group of suppliers able to meet immediate needs. Given Palau’s small market and limited supply availability, it is often necessary to procure from vendors who can consistently provide quality inventory.

We concur with reservations. While policy calls for equitable distribution of micro-purchases, during the pandemic it was necessary to procure supplies from reliable vendors who could meet urgent operational needs. Supply chain disruptions and Palau’s small market meant awards were concentrated among a smaller group of suppliers able to provide timely and quality inventory.

I believe this has to do with the sewer project. I was thrown into the middle of this. I don’t believe proper records were started or kept by the former Fiscal Officer. I only have what happened since I was here.

Corrective action planned: Management agrees with the material weakness and compliance finding for procurement and suspension and debarment. Full and complete process of issuing request for proposal (RFP) and securing bids have been explained and trained for the Chief Financial Officer and Chief Executive Officer. The District will comply within the standard framework of all interested bid parties and will be provided with an RFP stating selection committee, selection criteria, and date and time of electronic bid submission. If a sole source is appropriate, then the CFO will prepare a sole source resolution for the Board of Commissioners to review and approve during an advanced notice held meeting open to the public. The sole source document will include at a minimum one of the five designed sole source qualifications. Anticipated completion date: June - December 2025 Contact person responsible for corrective action: Viola Babcock, Interim Chief Financial Officer

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Government Accountability Office Green Book. Anticipated Completion Date: 12/31/2025.

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding Coventry Public School’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Coventry Public Schools will review the district’s current purchasing policy and make sure that it is following the criteria as set out in the 2 CFR sections 200.318 and 200.326. The policy will then be updated and communicated to all personnel involved in the procurement process. Name of Contact Person Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

CONDITION: The City of McKeesport contracted four (4) vendors for the purchase of seven separate purchases of equipment for the City. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. All of these purchases were procured through a cooperative purchasing group (COSTARS). The City was unable to 1) provide records sufficient to detail the history of procurement for these contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources. This is a repeat finding (2021-005) for the prior year. CRITERIA: Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the City must maintain sufficient records to detail the history of procurement. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200. 318(i) of the Uniform Guidance.

As part of our current review and revision process, the Organization plans to adopt the 2 CFR §200.320 procurement guidance and develop supporting policies and procedures to ensure compliance with federal standards. Additionally, the Organization will incorporate the standards outlined in 2 CFR §200.318 to further align our operations with Uniform Guidance requirements, reinforcing our commitment to meeting federal compliance standards. The Organization has prioritized the completion and distribution of the updated financial policies and procedures, including the 2 CFR §200.320 procurement guidance by December 31, 2024.

The County will adopt a procurement policy in compliance with the requirements of the Uniform Guidance. This will be done with an ordinance passed by the county board.

Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the serious nature of this finding and the compliance required with 2 CFR sections 200.318 through 200.327, as well as Part 1326 for vendor exclusions. The Interim Controller and Director of Finance will be revising procedures to document requirements for all procurement activities, regardless of type. We also understand these findings are repetitive from the 2021 audit; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2022 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. Resolution of this issue began in 2024 as staff were trained and provided the updated procedure to ensure all procurement activities adhere to the company policies. Continuing education will be provided in 2025 to ensure continued compliance with these policies. In 2025, a formal procurement system in the new ERP structure will be implemented and utilized for vendor quotes, requisitions and POs to ensure compliance. Periodic reviews of the procurement activities will be performed to ensure compliance with these procedures to mitigate the risk of continued deficiencies. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: December 2024

Effective immediately, as a condition to issue a payment, all purchases exceeding the federal limit will require (a) evidence that quotes from at least three qualified vendors were obtained or (b) a written and signed statement that there are no other vendors providing the goods or services or (c) a written and signed statement that the purchase was made to address an emergency as declared by federal or local governments.

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