Corrective Action Plans

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, the auditors recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Planned corrective actions: The university puts measures in place to guarantee that every employee who makes federal purchases on the university's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts. Name of Responsible Party: 1. Aaron Krantz, IT Director 2. Jeffrey Beehler, Physical Plant Director 3. Yolanda Maltos, Grant Accountant 4. Melissa Hill, Provost 5. Alysia Stevens, Controller 6. VP of Administration/CFO 7. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Diana Fitzpatrick, Director of Finance Anticipated Completion Date: April 30, 2024 Planned Corrective Action: When notified by the audit firm of the error in procurement procedures, district employees were notified of the correct procedures. This information has been and will continue to be made known to district employees who are delegated authority to procure goods and services during monthly leadership meetings. During this spring’s annual budget workshop with district staff, a brief training session will be held on Federal, State, and Board procurement policies and procedures. Also, a record of vetting vendors has been implemented this current fiscal year via the Sam.gov website.

The District agrees with the finding and will institute the additional training and review process recommended.

Finding 2023-001 Information on the federal program: Federal Program Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) – COVID-19 HEERF Minority Serving Institutions (MSIs) Federal Agency: U.S. Department of Education Federal Assistance Listing Number: 84.425L Award Year: July 6, 2020 – June 30, 2023 Criteria or Specific Requirement: Procurement, Suspension and Debarment Condition: The University’s procurement policy does not contain adequate documentation to demonstrate compliance with federal procurement regulations. (Deficiency) Corrective Action Planned: The University will review the federal procurement requirements and revise procurement policies to incorporate all required elements of the federal procurement regulations. Contact Person Responsible for Corrective Action: Sharon Maxwell, Senior Vice President for Business and Finance Anticipated Completion Date: October 31, 2023

FINDING 2023-009: Wage Rate Compliance Response: We are implementing robust measures to ensure adherence to prevailing wage standards in all future construction contracts. This includes the inclusion of prevailing wage clauses and the requirement of weekly certified payrolls as part of our standard contracting process. Additionally, it's important to note that for the projects referenced in this finding, we did obtain certified payrolls, it just wasn’t done weekly. These additional safeguards will ensure compliance with wage rate regulations and reinforce our commitment to fair labor practices.

Finding 2023-001: Procurement and Suspension and Debarment Description of Finding: The City’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: The City concurs. Corrective Action: The City will enhance their existing policies for procurement to be in accordance with Uniform Guidance Procurement Standards and plans to be adopted by June 30, 2024. Name of Contact Person: Henry Dachowitz, Chief Financial Officer Projected Completion Date: June 30, 2024

Auditee Response: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to when applicable. Corrective Action Plan: (1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Lane Mecham, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract – November 2023 Certified weekly payroll reports obtained from contractor – November 2023

United States Department of the Education 2023-002 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out 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: Management agrees with this finding. Management will update their purchasing policy to ensure compliance with Uniform Guidance. The of the contact person responsible for corrective action: Elio Longo

Program: Choice Neighborhoods Implementation Grants Federal Agency: Department of Housing and Urban Development AL #: 14.889 Federal Award Identification Number and Year: Various - See SEFA Pass-through Entity: N/A Type of Compliance Finding: N - Special Test and Provisions Internal Control Impact: Material Weakness Finding: The City did not provide evidence supporting the City's compliance with this requirement. Status: Resolved Corrective Action Plan: Since the CNI grant has ended, the corrective action plan will apply to future grants. When the City obtains future grants utilizing and/or funding projects in multiple City Departments, operating procedures will be in place to ensure compliance and the required grant documentation will centrally located and identified. Person(s) Responsible for Implementation: Jeffrey Williams, Director of City Planning, Telephone: (816) 513-8803; Email: Jeffrey.Williams@kcmo.org

Program: Choice Neighborhoods Implementation Grants Federal Agency: Department of Housing and Urban Development AL #: 14.889 Federal Award Identification Number and Year: Various - See SEFA Pass-through Entity: N/A Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: The City did not provide evidence supporting the City's compliance with this requirement. Status: Resolved Corrective Action Plan: Since the CNI grant has ended, the corrective action plan will apply to future grants. When the City obtains future grants utilizing and/or funding projects in multiple City Departments, operating procedures will be in place to comply with 2 CFR sections 200.318 through 200.326 to ensure compliance and the required grant documentation will be centrally located and filed. Person(s) Responsible for Implementation: Jeffrey Williams, Director of City Planning, Telephone: (816) 513-8803; Email: Jeffrey.Williams@kcmo.org

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.

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out 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 conflict-of-interest policy has been added to the fiscal policies. Management is in the process of enhancing the federal procurement policy to include sections 200.318 – 200.326. Name of the contact person responsible for corrective action: Lisa Maraia, CFO Planned completion date for corrective action plan: December 1, 2023

(1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Cary Reese, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract-October 2023. Certified weekly payroll reports obtained from contractor-October 2023.

The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable.

1780 Sloan Avenue Indianapolis, IN 46203 (317) 351-1534 To Whom It May Concern, This letter is in response to our Single Audit/Uniform Guidance Finding. We understand that we are to verify two items when ESSER funds are used for construction contracts over $2,000: 1. Verify that the required prevailing wage rate clauses are included in the contract—also known as Davis-Bacon Act compliance. 2. For each week in which work was performed under the contract, verify that the contractor submitted the required certified payrolls. Although we did state the contractor was to be compliant with all applicable laws and regulations, the contractor did not provide this information in a timely manner and we were subsequently unable to provide these requirements during the audit. Regarding Finding 2023-001, please know that our organization understands this requirement and will adhere to it moving forward. Our plan of action includes incorporating strict language of the requirement in both contract and bid documents, correspondence submitted weekly, and explicit penalties for a contractor if they are unable to comply, which could include withholding of payment or stopped work. In addition to the measures above, I will be responsible to ensure all contractors are following these requirements. If you have any questions, please do not hesitate to contact me. Best Regards, Luke Kahren Chief Operating Officer luke.kahren@vcpindy.org (317) 351-1534

Special Tests - Wage Rate Requirements Federal Program: Education Stabilization Fund (ALN 84.425D & 84.425U) Federal Agency: U.S. Department of Education Federal Award Year: 2022-2023 Individual responsible for corrective action: Rosemarie Gomez, Federal Programs Director Date corrective action will be implemented: September 20, 2023 Corrective Action Planned: Response: In FY 2021, our Valley View ISDs federal programs office prepared a required checklist to document certification of compliance with the state and federally funded purchases. This checklist had been in use for over 2 years and at no time were other requirements noted. Corrective Action: On September 20, 2023, when Valley View ISDs Federal Programs Department was notified that the Davis- Bacon wage compliance item was missing from the checklist, it was promptly added, and the district has required that all contractors or subcontractors provide documentation to support wage compliance.

Individual responsible for corrective action: Anna S. Arredondo, Federal/State Program Director Melissa Trevino, Purchasing/Fixed Assets Coordinator Date corrective action will be implemented: November 2023 Corrective action plan: Federal/State Department administrator will review all required compliance documentation and expenditures allowances for grant/federal. Federal/Sate Department will implement internal controls for ESSER funds to receive required documentation for the duration of the contracted services and ensure documentation is sufficient prior to submitting invoices for payment. The Purchasing/Fixed Assets Coordinator will confirm with Federal/State Programs that all required ESSER documentation is provided with certified invoices before any payment is processed.

Views of Responsible Officials and Planned Corrective Action: The University agrees with the finding, a revised policy has been drafted and was approved in September 2023.

Contact Person Darren Albrecht Planned Corrective Action Activities Director Jon Koehmstedt 1548 School Road 701-352-1930 701-352-1943 Fax The District will plan to get payroll registers monthly from contractors moving forward. Planned Completion Date The planned completion date is June 30, 2024.

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

Material Weakness in Internal Control Over Compliance (Federal Award Program) The City will develop and implement formal written procedures for the management of Federal award expenditures and procurement activities. All fund transfers will require documented approval by authorized personnel. Procurement processes will include verification of vendor eligibility, compliance with bid law, and retention of supporting documentation. Staff will be trained on federal compliance requirements. Responsible Party: Robert Nielson, Temporary Fiscal Administrator Timeline: December 31, 2025

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.

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.

Finding Reference Number: MW2022-006 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: Vendor status for 2022 recipients was retroactively evaluated by CUAHSI staff and certified by management during calendar year 2024. Records were organized and filed in a secure, centralized document management system. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding closed, as current practices comply with established policies and procedures. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete