Corrective Action Plans

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.

Corrective Action Plan: Housing Resources, Inc. will review and update the current procurement policy to clarify competitive bidding thresholds and approval process for single source purchases. Once approved by the organization’s Board of Directors, the policy will be reviewed with all staff. Additionally, we will identify a specific staff person to manage vendor and contractor relationships including solicitation, bid process, selection, onboarding, etc. Documentation will be kept throughout the process should bids be required. Anticipated Corrective Action Plan Completion Date: October 31, 2025 Contact Information: For additional information regarding this finding please contact Trena Bond, Executive Director, at (414)461-6330.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

FINDING 2024-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Darrin Boas Contact Phone Number and Email Address: 812-522-4020; dboas@seymourin.org Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Management developed, adopted and implemented a procurement policy for federal purchases that aligns with the requirement of the 2 CFR 200 Uniform Guidance. This process includes steps within the interview and application process to ensure contractors and subrecipients are eligible (not suspended, debarred, or otherwise excluded) to enter into an agreement, contract, or subaward with the City. The contract in question was agreed to during last year’s audit and part of an overall project/grant overseen by Schneck Hospital entered into in 2021. Going forward, the Clerk Treasurer will review the agreements with the vendors who are being paid from federal grant monies to ensure that the procurement policy is being followed and proper documentation is being obtained based on the procurement method. Anticipated Completion Date: Completed. The City adopted Ordinance 35 on November 25, 2024. This was the effective date of correction.

Going forward, we will obtain and retain quotes via email and ensure that a sufficient number of qualified sources are solicited, in accordance with procurement guidelines.

Description: Significant deficiency in procurement compliance. Planned Corrective Action: CGS will revise its internal procurement policies to ensure that all amounts, regardless of vendor or how they will be charged within the accounting system over the micro-purchase threshold, currently $10,000.00, be considered in the aggregate and formally bid out accordingly with written responses retained internally as support. Additionally, in cases where specific agency approval is required for a procurement, such will be obtained before any awards are made. Completion Date: October 1, 2025 Responsible Person: Keith Peregonov, VP for Finance, Human Resources and Operations

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/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management and finance staff will more closely monitor when non-payroll expenditures are charged to federal grants and adhere to procurement policy when over the required threshold that requires board approval over equipment, supplies, and services $10,000 and 3 written bids when over $100,000. Additionally, finance staff will seek out training from contracted third-party consultant when documenting procurement items to ensure that all documentation required is maintained. Further, the procurement policy will be reviewed on a regular basis to ensure that personnel involved in procurement are educated in regards to the policy and procedures. Name(s) of the contact person(s) responsible for corrective action: Jeremy Runde, Controller Planned completion date for corrective action plan: June 2025

FINDING 2024-03 Finding Subject: Water and Waste Disposal System for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The Clerk Treasurer will work with the council and town attorney to make sure we are following the procurement policy and that we are compliant with the Federal and State guidelines. If a new project or a current project is being extended to a significant amount; during a council meeting, we will state that we are retaining a certain vendor for the project and explain why we are using that vendor. Anticipated Completion Date: August 1, 2025

In FY24, the Food Service Department piloted a recurring “Pizza Friday” program as part of its student lunch offerings. The District utilized Domino’s due to its demonstrated reliability, familiarity with school food service requirements, and consistent performance. The total annual cost of the purchases exceeded the federal micro-purchase threshold of $5,000. As a result of this finding, the District has updated its internal procurement practice to ensure multiple quotes and/or participation in approved consortiums and purchasing co-ops for services anticipated to exceed this cost. Additionally, the Board has updated policy to increase the threshold from $5,000 to $10,000.

Single Audit Finding: 2024-001 Federal Agency Name: Colorado Department of Transportation  Program Name: Formula Grants for Rural Areas and Tribal Transit CFDA #: 20.509 Finding Summary: Procurement and Suspension and Debarment, Significant Deficiency in Internal Control over Compliance. Responsible Individuals: Heidi Wise - Acting Deputy Chief Financial Officer, Marisa Rupp - Grants and Contracts Specialist, Bob Grogan - Purchasing Manager, Sarah Hill - Transportation Director, Calia Kimball - Transportation Specialist Corrective Action Plan: The City of Durango concurs with this finding and has planned steps to strengthen its internal controls related to procurement and suspension and debarment. In response, the City will implement a formal, standardized procurement process for these services, in coordination with the Risk Management division. This process will be adopted on a citywide basis and occur annually to ensure consistent application and compliance with federal and state regulations. To further reinforce compliance and oversight, a citywide Request for Proposals (RFP) for these types of services will be initiated in the coming weeks. The Transportation Director will coordinate with the Safety/Risk Administrator to lead this effort. Additionally, the City has scheduled an organization-wide training session to reinforce key procurement policies and best practices, with a focus on suspension and debarment compliance. Additionally, a new Purchasing Policy was adopted in early 2025, which includes enhanced documentation and verification requirements, specifically addressing procurement documentation - suspension and debarment checks for vendors. These measures are designed to ensure compliance with applicable procurement standards and reduce the risk of future deficiencies. Ongoing training and monitoring will be conducted to verify continued adherence and to promote accountability across all departments. Anticipated Completion Date: Implementation activities for the procurement in question, will begin in the coming weeks, with the RFP process and staff training scheduled for completion in the third quarter of 2025.

The City concurs with the observation and will implement procedures in 2025 as recommended.

Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency and accountability in our operations. Managements Response to Audit Finding on inadequate recording of procurement history or justification: 1. Review and Update Procurement Policies:  We will conduct a thorough review of our current procurement policies and procedures to identify any gaps or areas requiring improvement.  Updates will be made to ensure that our procurement policies align with federal regulations, including those related to suspension and debarment. 2. Training for Staff:  We will provide comprehensive training for all staff involved in the procurement process to ensure they understand the updated policies and the importance of maintaining proper records.  Training will include guidance on documentation requirements, vendor selection criteria, and compliance with federal regulations. 3. Implementation of Record-Keeping System:  We will implement a centralized, secure, and user-friendly record-keeping system to document all procurement activities.  This system will include templates and checklists to guide staff in capturing all necessary information, including vendor selection, bid evaluations, contract awards, and verification of suspension and debarment status. 4. Regular Monitoring and Audits:  We will establish a schedule for regular internal audits of the procurement process to ensure ongoing compliance and to identify any potential issues promptly.  Findings from these audits will be reviewed by senior management, and corrective actions will be taken as needed. 5. Vendor Verification:  We will enhance our procedures for verifying the suspension and debarment status of potential vendors before awarding contracts.  This verification process will be documented and retained as part of the procurement records. Conclusion: FASEB is committed to addressing the findings related to procurement and suspension and debarment. We believe that the steps outlined in our corrective action plan will ensure compliance with Federal regulations and enhance the integrity and transparency of our procurement process. We appreciate the opportunity to improve our practices and will provide updates on our progress as requested.

Year Ended: October 31, 2024 Finding Number: 2024-001 Name oflndividual Responsible for Correction Action: Alissa Rodgers, CFO Cause: Austin Street was previously in compliance due to using a Sole Source Provider for Food that provided the food services as well as the food supply vendors. August Street discontinued services with the food service provider however maintained the food supply vendors. Since they were not new vendors it was misunderstood to pass those vendors through procurement once again since the sole source was no longer connected to the food program. Corrective Action Plan: On April 17, 2025, Austin Street Center's business office has published and distributed an RFP for food vendors to comply with procurement requirements as food costs are usually more than $250,000 per year. ProcW"ement Processes have been followed in all other areas of the organization and Austin Street is placing month end procedures in place to ensure no vendors unexpectedly rise above thresholds that require additional procurement or analysis.

FA 2024-001 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: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $77,285 Prior Year Finding: FA 2023-001 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: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The new policy addresses the three types of procurement under CFR 200.320 informal and formal procurement and noncompetitive procurement. Thresholds have been set for Micro purchases and thus simplified procurement under informal practices. Formal methods include Sealed bids and Proposals when sealed bids are not appropriate.All checks are handled in accordance with the new check writing policy and have the necessary documentation to support the purchase and is filed in such a manner to be available for future reviews. This documentation will be made available to the Authority's fee accountant.All procurement actions will be handled in accordance with the new procurement policy and CFR 200.Proposed Completion Date: Immediately

2024-001 (Significant Deficiency over Compliance): Insufficient Design of Procurement Policy Criteria: Under CFR 200.320, three types of procurement methods are outlined based on the dollar amount and nature of transactions. Condition: The Organization’s existing procurement policy outlines the three methods described under CFR 200.320. However, the policy does not incorporate sufficient monitoring procedures to ensure compliance with the procurement policy Questioned Costs: There were no questioned costs associated with this finding. Effect: This error potentially resulted in the payment of higher prices for goods and services, violating federal procurement regulations. Planned Corrective Actions: The Organization agrees with the finding and will review and revise its procurement policies and procedures to align more closely with current Uniform Guidance and establish monitoring procedures to ensure compliance with CFR 200.320. The Organization will provide additional training to employees and board members to ensure policies and procedures are being followed.

The District of Columbia Public Library (DCPL) concurs with the auditor’s findings and recommendations. Management acknowledges the finding regarding the procurement that was awarded prior to receiving the federal funding and the procurement did not fully adhere to the standards outlined in 2 CFR Section 200. The Procurement was awarded under the District’s Municipal Regulations policies and procedures, we recognize that the 2 CFR Section 200 requirements are stricter. Effective June 12, 2025, DCPL will ensure that all Procurements comply with 2 CFR Section 200, including procurements awarded prior to receiving Federal funding. This includes: • Enhancing our internal review process and documentation to confirm the funding source and ensure Federal procurement regulations are followed. • Identify training for Procurement, Budget and Program Staff on Federal grant compliance and Procurements that fall under 2 CFR Section 200. Contact: Richard Reyes-Gavilan, Executive Director Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendors were not excluded from federal contracts due to debarment or suspension. Corrective Action Taken: Procurement findings: 1. Performance Foodservice had two (2) invoices dated May 2023 (FY23) paid in FY24. For FY23 the BOE had a contract with Performance. The invoices were for prior year. No purchases were made in FY24, only payment from FY23 purchases. BOE believes the purchasing policy was followed. 2. Sardilli Produce, had 3 PO’s entered in FY24. One PO was for $80,000 for yearly invoices. 58 invoices were charged to PO. Average invoice total was $1,289. The approved PO did not follow purchasing policy. Suspension and Debarment addressed in 2024-005. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Finding 2024-003 Federal Grantor: United States Department of Health and Human Services Planned Corrective Actions: Monthly Suspension and Debarment files will be reviewed, and documented approval will be retained within the monthly files. Responsible Official – Dawn Ksepka, VP of Finance and System Controller Anticipated completion date –June 30, 2025 Management agrees with the finding. Remediation: Starting June 2025, the monthly suspension and debarment file will be reviewed. A signed statement confirming its accuracy will be included post-review. The accounts payable standard work document will be updated accordingly.

Finding 2024-002 Federal Grantor: United States Department of Health and Human Services Planned Corrective Actions: Responsible Official – Dawn Ksepka, VP of Finance and System Controller Anticipated completion date – July 31, 2025 Management agrees with the finding. Remediation: Fairview updated its internal control processes to better retain and document sole source procurement justification before entering vendor agreements. A standard form for sole source justification will be implemented to enhance documentation.

Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures related to procurement in March of 2024. See FY23 Corrective Action Plan. However, the one procurement sample that was cited as not including “documentation of bidding, alternative price quotes or sole source documentation” contained a sole source justification that was developed before implementation of the FY23 Corrective Action Plan. The sole source justification was based on the specialized knowledge and specific expertise. Procurement samples for purchases or contracts after the implementation of the FY23 Corrective Action Plan, show compliance of adequate bidding, price quotes or sole source documentation consistent with 2 CFR 200. The NWIFC will continue to implement the FY23 Corrective Action Plan, by requiring NWIFC managers and their staff to be responsible for soliciting bids or developing sole source justifications for procurements and contracts consistent with 2 CFR 200. The Contract Specialist will ensure that bid solicitations and sole source justifications are properly documented and filed with each contract. Similarly, the audit noted that certain suspension and debarment samples selected, before the FY23 Corrective Action Plan was implemented in March 2024, lacked documentation of a suspension and debarment review prior to doing business with vendors. In response, the FY23 Corrective Action Plan, put into effect in March 2024, included measures to ensure that both new vendor and annual reviews are documented. The Accounts Payable department will continue to conduct suspension and debarment reviews for all new vendors before conducting business and perform annual reviews of all vendors, in line with the FY23 Corrective Action Plan. Anticipated completion date: Completed March 2024.

The Division will formalize and adopt a procurement policy. This will also include a suspension and debarment check of vendors. Anticipated Completion Date: 8/1/25. Responsible Contact Person: Yohannes Gedlu, NW Divisional Finance Director & Julie Luft, NW Social Services Director

The City concurs. The City is revising its policies and procedures for federal award programs to include procedures related to simplified acquisitions.

CORRECTIVE ACTION PLAN Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in Monroe Community Mental Health Authority’s (MCMHA) Single Audit report for the year ended September 30, 2024, and corrective actions to be completed. Finding: 2024-001 – Procurement, Suspension and Debarment Auditor Description of Condition and Effect: The CMHSP did not document the noncompetitive procurement process pursuant to 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Auditor Recommendation: That the CMHSP review/update policies and procedures to ensure that formal procurement methods are documented, and verification of suspension, debarment, or exclusion is conducted prior to entering into a contract. Corrective Action: Management acknowledges the situation and is developing process and procedure to correct this going forward. Responsible People: Chief Financial Officer and Chief Operating Officer. Anticipated Completion Date: September 30, 2025