Corrective Action Plans

(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

CORRECTIVE ACTION PLAN (Concerning Finding 2022-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2022-004 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted a new Procurement Policy that addresses this deficiency. This policy was approved and implemented by the Select Board at their January 23, 2024 meeting. Anticipated Completion Date: Completed January 23, 2024.

Recommendation: We recommend the college implement policies and procedures to ensure all procurement documentation is complete and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement policies are in place and trainings have been provided for Purchasing and Accounts Payable staff to ensure that all Procurement documentation is included in payment packets. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

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

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

Finding Number: 2022-006 Condition: Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarment rules. Planned Corrective Action: Management will implement written policies and procedures over procurement, suspension, and disabarment that conform with Uniform Guidance Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: 06/30/2025

2022-004 Procurement Criteria: The Town must follow the procurement standards set out at 2CFR Section 200.318 through 200.326. This requires bids to be obtained for purchases ranging from $10,000 - $250,000. The Town currently has policies in place to utilize the state library which is a listing of approved vendors for potential purchases of over $50,000. The CFR does allow an entity to increase the lower limit from $10,000 to $50,000 in certain circumstances. One of the conditions is that the entity qualifies as a lowrisk entity. The Town currently does not qualify as low risk; therefore, the Town does not qualify for the increase of the lower limit from $10,000 to $50,000. Sole source vendors are the exception to this rule. Condition: The Town did not obtain three bids for over $10,000 purchases. Did use the state library to identify eligible vendors but failed to obtain the required three bids. Cause: The Town relied on the state library which is not an approved listing according to the CFR. Effect: The Town is not in compliance with 2CFR Section 200.318 through 200.326 and therefore, the Town has the possibility of not being able to renew contracts in the future. Recommendation: We recommend that the Town obtain the required three bids for purchases over $10,000. Views of Responsible Officials and Planned Corrective Actions: The Town has hired an Asset Support Specialist to help ensure compliance with such requirements and understands the importance of meeting the requirements.

Contact Person Dan Juve Planned Corrective Action The District will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of fiscal year 2023.

Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.

Management concurs with the audit finding. The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where City personnel are not available or qualified to perform.

The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

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

Finding No. 2022-006 KCHC agrees and acknowledges the findings related to procurement and suspension and debarment compliance. Since the hiring of new procurement personnel in September 2024, the Finance head has been actively providing regular training to procurement and finance staff, ensuring they are well-versed in federal regulations. Additionally, KCHC has implemented enhanced systems for procurement management and documentation. 1. Onboarding and Training for New Procurement Personnel: The new procurement personnel will undergo comprehensive training on KCHC's procurement policies, federal regulations (2 CFR Part 200), and the use of ProcurementExpress and DocuSign systems. This training ensures the new staff member adheres to procurement procedures, including proper documentation. 2. Ongoing Training for Procurement and Finance Staff: Regular training sessions are conducted to reinforce awareness of federal procurement regulations and KCHC’s internal policies. The focus will be on maintaining adequate documentation, ensuring open competition in procurement processes, and complying with suspension and debarment regulations. 3. Strengthening Monitoring and Internal Audits: KCHC will continue to enhance internal monitoring and audit activities. The Finance department will collaborate with procurement personnel to review all transactions, ensuring that procurement packages include price quotes, purchase orders, and contracts as required. Internal audits will be performed regularly to identify and rectify any documentation gaps. 4. Optimizing Existing Systems: The integration of ProcurementExpress with the accounting system and the use of DocuSign for approval routing will be fully utilized to ensure that all procurement steps are documented and compliant with federal standards. These systems will also ensure that records are readily available during audits. 5. Addressing Repeat Findings: To address the repeat nature of this finding, KCHC will closely monitor the implementation of corrective actions. The accountant will lead efforts to track procurement documentation compliance, providing regular reports to CFO to ensure that procurement activities align with both federal and internal requirements. Implementation Timeline: Completed as of September 30, 2024 with continued updates and monitoring. Responsible person: Arlene Deleon Guerrero, CFO

Department of the Treasury, Passed through North Dakota State Water Commission Federal Financial Assistance Listing 21.027 COVID-19 - Coronavirus State and Local Discal Recovery Funds Procurement, Suspension, Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: General Manager (Vacant) and Jan Lee, Office Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements Anticipated Completion: December 31, 2024

Federal Program Name/Assistance Listing Title: Federal Transit Cluster Federal Assistance Listing Number: 20.507 State Program Name: State Urbanized Area Formula Program, State Formula Grants For Rural Areas Contact Person: Ted Ross, Acting Executive Director Anticipated Completion Date: 1/1/2025 Planned Corrective Action: The Transit District has changed most of the personnel in Finance and Administration, which improved expertise and performance. The Transit District is also working on a new comprehensive Finance and Administration policy which will include all new controls implemented. Procurement procedures will be updated and strengthened in the new policy including ensuring documentation of quotes and suspension and disbarment are checked, reviewed, and documented in the procurement file.