Corrective Action Plans

The Organization plans to use their procurement policy to ensure they are in compliance with the procurement standards.

Recommendation: We recommend that the Organization update its procurement policy to include all federally required elements of such policies for federal award recipients under the Uniform Guidance. We also recommend that the Organization document and maintain evidence of its suspension and debarment procedures to be in compliance with requirements specified in the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review and update its procurement policy to incorporate all federally required elements of the Uniform Guidance. The Organization will also document its suspension and debarment procedures and maintain evidence of the performance of such procedures. Name of the contact person responsible for corrective action: Ali Butler, Director of Finance Planned completion date for corrective action plan: July 2024 If the Department of Interior has questions regarding this schedule, please call Ali Butler at 720-865-3770 or ali.butler@botanicgardens.org.

Finding Summary: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids were not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Responsible Individuals: Andre Stringfellow, CFO Corrective Action Plan: Procedures will be developed and staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation. Anticipated Completion Date: August 2024

Management concurs with this finding. Management is reviewing and revising its procurement policies to comply with state and local laws, the standards of the CFR, as well as reflect current operating procedures.

Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements. The City has initiated to hire an adequate amount of staffing which will allow the Purchasing Department to enforce the suspension and debarment process during the procurement process; which will include checking sam.gov and other appropriate federal resources to check for vendor suspension and debarment.

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implement formal procurement procedures aligned with federal regulations, including thresholds for prior‐purchase authorization and vendor checks for suspension and debarment. Staff training will be conducted to ensure competency, and oversight mechanisms will be strengthened through regular monitoring and integration of SAM verification processes. Comprehensive documentation and record‐keeping practices will be established, with periodic reviews to facilitate continuous improvement. Through these actions, the YWCA aims to enhance compliance with federal procurement standards and ensure transparent and accountable procurement practices.

Federal Agency Name: U.S. Department of Transportation; U.S. Treasury Department; Assistance Listing Number(s): 21.027; 20.507; Program Name(s): Federal Transit Cluster - FTA 5307 CARES Act 2020; COVID-19 Coronavirus State and Local Fiscal Recovery Funds Material Weakness in Internal Control Over Compliance – Compliance Requirement – Procurement, Suspension, and Debarment Finding Summary: The City’s purchasing policy is missing elements required by Uniform Guidance, the City did not verify vendors were not suspended or debarred before entering into contracts with vendors, and elements required to be included in contracts with vendors paid using federal monies were missing from contracts. Corrective Action Planned: The City concurs with the auditors’ findings. The City is working to develop an updated purchasing policy, improve processes, and continue training staff around purchasing and contracting to ensure Uniform Guidance requirements are met, and specifically, that vendor contracts include elements required when using federal monies, and the vendors are checked against the suspended and debarred listing. Responsible Individual(s): Mark Hagedorn, Finance Manager/Treasurer; Brooks Slyter, Assistant Finance Manager Anticipated Completion Date: March 2025

The School District will follow proper procurement procedures related to food purchases.

Finding Number 2023-001 Contact Person(s): Rick Johnson, VP of Finance and Administration Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Corrective action planned: The Seattle Aquarium will provide training for employees involved in procurement exceeding the simplified acquisition threshold to ensure they are aware of the various procurement methods and requirements. Review of the procurement process by the Finance Department will be required for such planned purchases. Anticipated completion date: June 30, 2024

Procurement and Suspension and Debarment Recommendation: We recommend that the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will implement additional policies and procedures in relation to ensuring vendors used are not suspended and debarred. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: April 2024

Item 2023‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all current contractors and subcontractors regarding the wage rate requirements for contracts in progress and has implemented additional procedures for future projects effective January 1, 2023. These additional procedures include the Chief School Financial Officer (CSFO), Linda Harper, reviewing all proposed construction contracts for inclusion of the prevailing wage rate clause as part of the bid process prior to expenditures being made. The CSFO will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

FINDING 2023-010: Wage Rate Compliance Response: The District will implement internal controls to ensure that all construction vendor contracts will include prevailing wage clauses and weekly certified payrolls are received.

2023-002 U.S. Department of Transportation, National Infrastructure Investments: Better Utilizing Investments to Leverage Development (BUILD) Grant Assistance Listing Number 20.933; Procurement Material Weakness in Internal Control over Compliance Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. The Port Authority’s formally documented policy pre-dates Uniform Guidance and does not include many of the necessary procurement provisions. Corrective Action Plan: An updated Procurement Policy is being drafted to meet the standards set forth in 2 CFR 200.317 to 220.237, then reviewed and approved by our Board at the next appointed board Meeting. Expected Completion Date: March 2024 Responsible Individuals: Kimbra Scott

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so its clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2024.

FINDING 2022/2023-004: Wage Rate Compliance Response: The District has policy# 8502 already in place and was adopted in April of 2022. The next time a construction job comes up in the district and is over $5000.00 and being paid out of federal funds, the district will ask for payroll reports that show prevailing wages.

Initial Fiscal Year Finding Occurred: 2023 Federal Agency Name: U.S. Dept of Housing and Urban Development Program Name: Continuum of Care CFDA #: 14.267 Finding Summary: Significant Deficiency over Internal Controls over Compliance. Procurement, Suspension, and Debarment During testing, it was identified that the Organization was not following its procurement policy. Responsible Individual: Theresa Perkins, Chief Financial Officer Corrective Action Plan: The NAC leadership team is responsible for the following and will report on the following for FYE 2024: Provide a final Procurement Plan that has been reviewed and updated and approved by the Board. Anticipated Completion Date: June 30, 2024

Official Responsible for Ensuring CAP Lorie Werle, business manager, will be responsible to ensure that the appropriate measures are taken. Correcting Plan The District will provide Lorie Werle, business manager, necessary training. The Planned Completion Date of CAP Immediately

Finding – Internal control deficiencies over procurement requirements Name of contact person: Lane Millar, Finance Director Corrective action: The City will ensure that employees receive comprehensive training on procurement requirements as a prerequisite before undertaking those responsibilities. Proposed completion date: March 1, 2024

MW Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to add in the other methods of procurement to ensure compliance with the Uniform Guidance and follow proper document retention procedures. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2024

Contact Person Theresa Brien-Knutson, Business Manager Planned Corrective Action The District will plan to get payroll registers monthly from the contractors moving forward. Planned Completion Date June 30, 2024

Contact Person Theresa Brien-Knutson, Business Manager Planned Corrective Action The District will plan to get payroll registers monthly from the contractors moving forward. Planned Completion Date June 30, 2024

Somerset County Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Audit Period: July 1, 2022 through June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING- MAJOR FEDERAL AWARD PROGRAM AUDIT U.S Department of Agriculture 2023-001 Paper/Chemical Product Contract Recommendation: The Board should follow its established procedure and policy providing for competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Board has entered into a competitively sourced contract with FPC Holding, Inc. as of December 2023 for the purchase of these products. Name of contact person responsible for corrective action: Linda R. Johnson, Director of Finance Planned completion date for corrective action plan: December 1, 2023

Finding 2023-002 Procurement Corrective Action: TPOCC has updated its Finance Manual, inclusive of a procurement policy in compliance with Uniform Guidance (2 CFR Part 200). We have also had all management staff who deal with programs funded by Federal Funds attend training on Uniform Guidance. We will continue to have staff attend these training courses to ensure that they are familiar with the requirements of Uniform Guidance. We have also begun implementing a procurement system (Pairsoft Paramount Workplace) and anticipate a go live of April 1st, 2024. This will help ensure our procurement policies are implemented and followed uniformly. Person Responsible: Finance Director, Lacy Meneses and CFO, Will Goodall Timing for Implementation: Currently in progress and procurement software will Go Live on April 1st, 2024. Document ID: b51a2bdf940fc8367245121fabb689a6083edd8e9deb8925c16c8fec9313f6b8 Page 1 Summary Schedule of Prior Year Findings and Questioned Costs Turning Point of Central California, Inc. did not retain procurement records to support its assertion that it is contracting with vendors that provide the best prices. Turning Point of Central California, Inc. has not updated its procurement policy to comply with the Uniform Guidance (2 CFR Part 200). This finding was first reported in the June 30, 2021 audit, issued in June 2022, and Turning Point of Central California, Inc. did not have adequate time to implement its corrective action plan during the year ended June 30, 2023. Questioned Costs: None

2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation supporting that vendors were reviewed for suspension and debarment. There was also no documentation for review of the procurement transactions tested. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: Changing the personnel involved has solved much of the problem, also the full awareness of what needs to be retained has also been explained to management. Management intends to add a Director level executive in the spring of 2024 to fully review and revise where necessary all standard operating procedures, including that of procurement. If/when funds from federal sources are used, those expenditures will be reviewed monthly. Specifically, this will mean: -Maintain EIDL‐sourced funds in a separate bank/account - Have single authorization for any movement/usage of funds in EIDL account - If/when funds from EIDL are used, have a written statement for purposes and documentation produced for use at the time of request Responsible Individuals: -Maintain separate account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024

Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Corrective Action: School did not have an HR Manager for school year 2022‐23 and the School recently hired an HR Manager. The Business Manager, with the help of the HR Manager, will ensure that School policies with sealed bids will be followed. The Business Manager will maintain all quotes  and  documentation  from  vendors.  The  School’s  current  policy  will  be  reviewed,  and  language will be added to address quotes and thresholds.