Corrective Action Plans

Recommendation – We recommend that management revise policies to ensure proper vendor compliance in the future. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.

FINDING 2024-001: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement policies. Corrective Action Plan: Management will design and implement a control to review cost transfers from non-federal awards to federal awards to ensure we follow our procurement policies. This will be achieved by adding a new step to the non-payroll cost transfer form that requires the requestor to include a copy of the Procurement authorization form if the procurement policies apply. The Procurement authorization form documents the process, rationale, and justification for procurements. If the purchase being transferred did not go through the appropriate procurement procedures at the time of purchase, then the transfer from the non-federal award to the federal award will not be allowed. Management will also provide additional training around procurement and our related policies and ensure staff involved in this area are aware of the new step embedded in the non-payroll cost transfer form. Remediation Date: July 2025

Views of Responsible Officials: BCHC is in the process of composing a formal procurement policy, which will address requirements for open competition and establish thresholds for different procurement amounts/processes. The policy will clearly outline the conditions where a noncompetitive purchase is allowable. We anticipate having this policy written by June 1 and will submit to the BCHC Board for review and approval. I

Finding 2024-004 Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Lincoln’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management is working with our current auditors to update the Town’s procurement policies to be in compliance with Uniform Guidance. Name of Contact Person John Cimino, Finance Director Projected Completion Date 6/30/2026

Reference Number: 2024-001 Description: Procurement Corrective Action Plan: The Organization will revise its procurement policy to align approval thresholds with current operations and best practices. Organization will then train staff involved in procurement of the revised policy and will ensure compliance before payment is made which would violate its policy. Anticipated Corrective Action Plan Completion Date: June 30, 2025. Contact Information: For additional information regarding this finding please contact Stephen Bauer, CEO at 414.345.3240.

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200 and management's internal policies and procedures related to procurement, suspension, and debarment. Planned Corrective Action: Management agrees with the improvement of documentation of procurement, suspension, and debarment. As noted below, purchasing policies are being followed, but were not always formally documented. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses. The findings noted three procurement contracts that were more than $50,000 that did not properly document the rationale for selection and/or sole procurement. The first contract was a single source provider for the replacement of thermostats. Other heating and air conditioning vendors would not handle the replacement of the thermostats as it was not their equipment. There was also a preventative maintenance agreement with the vendor: Phoenix Heating and Air. We will document the use of a single source contractor as allowed in our purchasing policies. We did follow the other control procedures regarding contract approvals, obtaining Certificates of Insurance and verifying completion of the work. The second contract was related to our website and marketing company: Brand Vibe. We did an open bid process, two years earlier, and renewed the contract without a formal bid process. As mentioned above, we did follow the proper approval process and verified the work was completed. The total of this contract for FY 2024 was $74,665, however only $3,600 was charged against the federal grant. Going forward, we will document the rationale for renewing the contract. The third contract was for a bi-lingual APN, with a Psych. Certificate, who was a former employee. She wanted to work part-time, and we switched her to a 1099 employee. With her experience and work record, we allowed her to transition to a part-time contractor. Our experience finding bi-lingual providers has been difficult, and the agency costs are almost double the cost paid for this contractor. The amount charged to the Trauma-Informed Centers of Care was $47,769. In the future, we will formally document the selection and use of this contractor. As noted, we did have a formal contract. and all providers are approved by the Board. Management will make necessary revisions to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200. Specifically, management will ensure the history of procurement - whether obtained through quotes, formal competitive bids, or through non-competitive means – is documented, including evidence that a cost-price analysis was performed for all purchases in excess of the simplified acquisition threshold. Additionally, before entering a covered transaction with third parties, management will have a form completed by the outside parties stating they are not suspended or debarred from engaging in federal activity before entering a covered transaction. This form will be retained, and we will check and document Sam.gov, excluded parties listing. Contact person responsible for corrective action: Karen L. Williams, Chief Financial Officer Anticipated Completion Date: 06/30/2025

2024-001 Federal Program - Federal Program AL# 93.526 - Health Center Infrastructure Support - Significant Deficiency in internal control over federal award program and Noncompliance - Procurement Recommendation – We recommend that management reinforce adherence to the Center’s procurement policy by providing periodic training to all staff involved in the purchasing process, with a focus on the appropriate application of procurement methods in accordance with 2 CFR § 200.320. Additionally, management should implement a formal review and oversight mechanism to ensure that all procurement transactions exceeding established thresholds are properly evaluated on an aggregate basis, fully documented, and compliant with both internal policies and federal regulations. Action Taken – We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. the Center will conduct training for all relevant staff on the proper application of procurement thresholds and documentation requirements. Additionally, management will implement a procurement review checklist and approval process to ensure that all purchases are evaluated in accordance with applicable procedures. These corrective actions will be implemented by December 31, 2025.

Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: VariousThe University concurs with the auditors' finding. The University did not communicate the change in auditee status and the resulting impact on the micro-purchase threshold to Procurement Services in a timely manner. This oversight led to continued application of the higher $75,000 threshold after the University no longer qualified under 2 CFR 200.320(a)(1)(iv). To address this issue, management is implementing the following corrective actions: 1. Cross-Functional Communication Protocol – A formal communication protocol will be established between Accounting and Financial Reporting and key compliance stakeholders to ensure timely notification of changes in auditee status or other compliance-related designations following the completion of the annual financial statement audit. 2. Policy Update and Staff Training – Procurement policies and procedures will be updated to reflect the requirement that UAH is subject to the lower micro-purchase threshold. Staff will be trained to take appropriate action when the University either qualifies for or no longer meets the criteria for a higher micro-purchase threshold, including timely adjustments to procurement policies and procedures. 3. Monitoring and Review – The Controller’s Office will conduct an annual review of auditee status immediately upon issuance of the audited financial statements, with documented confirmation sent to key compliance stakeholders. The University expects to complete this corrective action plan by September 30, 2025. For follow-up questions or if you need any additional information, please feel free to contact Brad Cooper, Interim Chief Financial Officer, at jbc0038@uah.edu who is responsible for this corrective action.

The City will provide staff training on appropriate procurement methods and ensure that procurements relating to federal funds follow the procurement methods described in CFR 200.320.

2024-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the Village evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The Village immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Ryan VanDeWalle, Village Administrator and Melanie Wiskow, Finance Director/Treasurer Planned completion date for corrective action plan: The Village immediately began evaluating procedures and will implement as soon as possible.

2024-004 Coronavirus Relief Funds – Assistance Listing No. 21.027 Recommendation: CLA recommends the City review procurement policies for the entire City 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: The City will review procurement policies for the entire City to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Name of the contact person responsible for corrective action: Tammy Kasal, City Clerk/Treasurer Planned completion date for corrective action plan: December 31, 2024

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 vendor –– Beaver Valley Intermediate Unit ($332,200). 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 2024-2025 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: Voyager Sopris Learning ($49,117) and Questeq ($70,549). 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.

Annual July 1 filing of the Request for Approval for a Noncompetitive Proposal when Procuring Personnel-Based Services from a High-Performing Educational Service Center Under Ohio Revised Code 3313.843(J). This form was filed when I spoke with Adam and became aware of the oversight. The request was received and accepted by DEW for the period March 31, 2025-March 30, 2026. Moving forward the form will be filed for July 1 start date:

In the future the Treasurer will ensure proper procurement methods are utilized.

The district will obtain more information from the Ohio Purchasing Council going forward on future projects.

The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2024-2025 fiscal year.

Although procurement will be handled through several manager, MVRTD will implement a procedure that All procurements will be finalized and filed with the procurement manager. MVRTD will update it procurement policy to restate the timetable for operational procurements and define the filing of the documentation of each operational procurement above a specific dollar value ( to be defined).

Revise and standardize the Sole Provider Justification form to require all federally mandated elements under 2 CFR 200.320. Train all staff involved in procurement activities on the updated requirements and documentation standards. Implement a review and approval step within the new ERP system to verify that all sole-source procurements meet the full documentation standards before processing. Conduct periodic internal audits of procurement files to ensure continued compliance. Require management approval for any noncompetitive procurement exceeding micro-purchase thresholds.

2024-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2025 Corrective Action: Management agrees with the finding and recommendation set forth within. Prior to fiscal year 2024, noncompetitive procurements completed followed the prior procurement policy that did not align with Uniform Guidance as relates to noncompetitive procurement justifications. The Corporation has since completed its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. Training on the Uniform Guidance procurement requirements is now ongoing and is required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. NeighborWorks has also implemented a new contracts management system to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. During fiscal year 2025, management will implement additional controls to ensure expenses charged to federal programs on contracts entered into prior to fiscal year 2024 are in compliance with the procurement requirements of the Uniform Guidance. This process will involve reviewing all existing contracts that previously lacked compliant noncompetitive procurement justifications and implementing corrective actions as needed.

This error occurred during fiscal year 2022, when the architect for an upcoming project was chosen. We are in a very rural area, where architects are not easy to come by. For this project, we had decided to utilize a local firm we had a good track record with. We presented it to our board for approval, and it was approved by them at that time so we originally had thought we could justify with having them as a sole source vendor. At the time, the total amount of the project was unknown, and has even changed significantly since that date. However, come to find out, due to the size of the project it should have been bid out. We have revised our procurement policy since this date and have educated all staff on proper procurement procedures.

HCS currently has in place policy 2095-Procurement Standards, which requires obtaining 3 quotes for goods and services above $5000. This policy was not followed by the agency's leadership when the goods and services mentioned in this finding were procured, despite counsel recommending that it be followed. Corrective action included termination of the individual who violated policy. Beginning on 11/15/2024, the above-referenced policy has been, and will continue to be, adhered to.

Audit Finding Summary: 2024-002 The Organization did not establish or follow sufficient internal controls to ensure compliance with federal procurement requirements, including maintaining the required documentation for procurement activities. Corrective Action Plan: Contact Person Responsible for Corrective Action: Wendi Gephart, Federal Contracts and Grants Compliance Manager wendi@movementstrategy.org | (510) 956-3849 Planned Action: MSC recognizes the need for improved procurement documentation and internal controls. To strengthen compliance with 2 CFR 200.318-326, MSC will take the following actions. Revised Procurement Policies: MSC is updating its procurement policies and procedures to reinforce adherence to federal regulations, ensuring full and open competition in all procurement transactions. Enhanced Documentation and Record-Keeping: A comprehensive process will be established to maintain detailed procurement records, including justification for vendor selection, contract pricing, and competitive bidding results. This will ensure transparency and compliance with federal requirements. Staff Training in Federal Procurement Standards: MSC will provide training to staff on procurement regulations, including conflict-of-interest policies, documentation requirements, and competitive bidding procedures. Periodic Compliance Review: Internal review will be conducted periodically to verify compliance with procurement policies and federal regulations. MSC remains committed to continuous improvement in financial and compliance practices to uphold the integrity of its federally funded programs. Expected Completion Date: June 30, 2025

We will comply with the procurement policy. I have already submitted the information to ODEW for FY25.

Corrective Action Plan To comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a) the Board will obtain from multiple vendors on an animal basis price listings of commonly purchased items and or services to deternune lowest cost of items and or services available to be purchased from qualified sources. Anticipated Completion Date: April 1, 2025 Contact Person(s): John N. Godwin, Chief School Finance Officer