Corrective Action Plans

Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Condition: All construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act as supplemented by the Department of Labor regulations. This includes a requirement for the contractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Corrective Action Plan: Management will work with contractors to get provisions included in construction contracts in progress and ensure new contracts have required provisions and obtain certified payrolls. Person Responsible for Corrective Action: David Jones, Business Manager Anticipated Completion Date ? FY2023

Findings and Questioned Costs Related to the Federal Awards 2022-002 Material Weakness - Special Tests - Wage Rate Requirements The City will assign a responsible party to take training in the Wage Rate Requirements (Davis-Bacon Act) and be able to identify the required information on a certified payroll.

Findings Required to Be Reported by the Uniform Guidance Department of Education Finding: 2022-001 CFDA #: 84.425, 84.425D, and 84.425C Recommendation: We recommend the School Corporation implement a compliance review process over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: Subsequent to June 30, 2022, the School Corporation will work toward ensuring the certified payrolls are obtained. Name of Contact Responsible for Corrective Action: Stefan Pittenger, Director of Fiscal Affairs, 260.467.2035. Anticipated Completion Date: June 30, 2023.

2022-006 Special Education Cluster (IDEA) Recommendation: The School Corporation should design procedures and controls to ensure compliance with suspension and debarment provisions. Before entering into a contract, a check should be performed and retained to support the contractor status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation will check vendors on the SAMS site to verify the contractors are not suspended. Documentation of the verification will be retained. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

FINDING 2022-009: Prevailing Wage Rate Internal Control and Compliance Response: Going forward all construction using federal funds in excess of $2000 will have a contract stating the prevailing wage rate clause and submission of weekly certified payrolls.

Finding: 2022-001 Federal Agency Name: Department of Energy, passed through Colorado Governor?s Energy Office Program Name: Weatherization Assistance for Low-Income Persons CFDA #81.042 Finding Summary: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained on one instance of single-source vendor for services provided. Responsible Individuals: Emilee Powell, Executive Director and Marcy Child, Weatherization Program Director Corrective Action Plan: Housing Resources of Western Colorado will utilize a procurement checklist to ensure that all required procurement actions are undertaken and all required documentation is obtained for procuring contracts over the micro-purchase threshold under federal awards, in order to comply with Housing Resources? procurement policy and federal compliance requirements and will conduct additional training to ensure that all staff understand which actions are considered procurement actions. Implementation date: November 1st, 2022.

Views of Responsible Officials: The Organization is in the process of updated its procurement policy, so it aligns with the requirements set by the UG.

Finding Number: 2022-001, 2021-001 Contact Person: Shelly Kreger, Transit Director Anticipated Completion Date: July 31, 2023 Planned Correction Action: YCIPTA has implemented with the help of FTA guidance new procurement policies to help assure the procurement process is completed in a thorough and timely manner. All staff had to sign an acknowledgment receipt that they received and read the new policies. YCIPTA has been short staffed to start up the RFP process for the large expense items that have not been procured since last year. YCIPTA had since been able to hire staff to help with the process and anticipates starting with the Fuel Expense as the first procurement to rectify this finding. Additionally, the appraisal that was expected to be completed by July 31, 2022 was not completed. New completion date is also July 31, 2023.

Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The District has no procedure in place for review of vendors to ensure that they are not suspended or debarred before purchases are made in compliance Uniform Guidance and 2 CFR sections 200.318 through 200.326. Responsible Individuals: Peter Haapala, Superintendent Corrective Action Plan: The District will update their procurement process to include review of vendors to ensure that they are not suspended or debarred before purchases are made in compliance Uniform Guidance and 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: June 30, 2023

FINDING 2022-003: Prevailing Wage Rate Internal Control and Compliance Response: The District will notify contractors paid with federal funds of the prevailing wage requirement and require submission of weekly certified payrolls, prior to final payment.

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic will review the procurement standards set forth at 2 CFR part 200 and update our procurement and purchasing policies to include all required purchasing standards as required. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award. The anticipated completion date is 6/30/2023.

Finding 2022-001 Description of Finding Procurement and Suspension and Debarment Statement of Concurrence or Nonconcurrence The Town Concurs Corrective Action The Town of Plainville has taken corrective action to remediate this finding by working on a draft of a new procurement policy for the Town that incorporates the essential elements as outlined in 2 CFR sections 2000.318 through 200.326. Due to the COVID-19 pandemic, the Town was not able to formally implement this policy prior to June 30, 2022. The Town has formally approved and implemented the updated procurement policy in January 2023. Name of Contact Person Robert Buden, Director of Finance Completion Date January 9, 2023

2022-002?Procurement Corrective Action: Current Management is not able to confirm nor deny that appropriate documentation was not collected prior to payment, but highly doubts that it was not collected based on the reliability of the previous Grants Manager. Management notes that the vendor was specifically mentioned in the Grant submission. Management will ensure that purchasing SOP are implemented and selection of vendors is adequately documented. Management has secured project management software that will retain project documentation. This should ensure appropriate documentation is collected and available to all Management for the life of the project, until date of destruction. Person Responsible: Jennifer Hogan, Executive Director Completion Date: September 30, 2023

FINDING: 2022-004 Name of contact person: Bruce Peterson, Supervisor Corrective Action Plan: We have drafted a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200.326 that has been approved by the Township board on June 12, 2023. The policy has been submitted to the Township attorney for review, and will be finalized pending any modifications or recommendations by our attorney. Proposed Completion Date: Immediately.

FINDING 2022-007: Non-compliance with Wage Rate Requirements Response: All contracted work related to construction or remodeling that uses Impact Aid funds will require contractors to provide weekly payroll reports that guarantee the Davis-Bacon Wage statute is followed. District Clerk and/or Business Manager will ensure each contractor submits their certified payroll for each job before any payments are distributed to contractors for work completed.

2022-003 FINDING Contact Person ? CJ Holl, County Administrator Corrective Action Plan ? The County will implement procedures to ensure that federal procurement standards are followed for federal grant purchases. Completion Date ? Ongoing

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 Southwest Kansas Area Agency on Aging, Inc. respectfully submits the following corrective action plan for the fiscal year ended September 30, 2022. Name and address of independent public accounting firm: Kennedy McKee and Company LLP P.O. Box 1477 Dodge City, Kansas 67801 Audit period: October 01, 2021 through September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - Major Federal Award Programs Audit U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Title III Aging Cluster Title III B Supportive Services CFDA 93.044 Title III C Nutrition Services CFDA 93.045 Title III C Nutrition Services Incentive CFDA 93.053 Grant Period: Year ended September 30, 2022 Condition: The Organization did not have a written procurement policy to properly implement all the requirements of 2 CFR Section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Criteria: In accordance with 2 CFR Section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR 200.318 through 200.326 of the Uniform Guidance. Cause: The Organization?s procurement policy does not incorporate all the requirements of 2 CFR Section 200.318 through 200.326 of the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. Southwest Kansas Area Agency on Aging, Inc. Corrective Action Plan February 9, 2023 Recommendation: Management should continue to develop comprehensive written policies and procedures to administer all federal programs. Current written policies should be evaluated for inclusion of and compliance with Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements. If the Oversight Agency has questions regarding this plan, please call Rick Schaffer at (620) 225-8230. Sincerely yours, Rick Schaffer Executive Director 236 San Jose Drive Dodge City, KS 67801

Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement new policies and procedures to ensure that all expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Name(s) of the contact person(s) responsible for corrective action: Sherri Crow, Interim Director of Budget and Finance Planned completion date for corrective action plan: January 1, 2024

2022-004 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, 2023.

REFERENCE: 2022-101 CFDA NUMBER 84.425d ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2022 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Donella Jurado 2. Corrective action planned: Ensure weekly payroll reports are received weekly and reviewed in comparison with Davis-Bacon prevailing wage rate requirements. 3. Anticipated completion date: This has already been done for current fiscal year (FY22 06/30/2022) and FY2023 (07/01/2022).

Finding: 2022-004 SPECIAL PROVISIONS ? WAGE RATE REQUIREMENTS Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, and 84.425W Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 and S425C210015 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: Management will implement procedures and controls to obtain the necessary documentation to verify that contractors are in compliance with the wage rate requirements. Official Responsible for Ensuring CAP: Todd Tetzlaff, Director of Finance and Human Resources. Planned Completion Date for CAP: June 30, 2023.

FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF TRANSPORTATION 2022-002 Airport Improvement Program ? 20.106 Recommendation: Procedures should be put in place to ensure weekly certified payrolls are received from construction contractors for conformance with Uniform Guidance. Action Taken: Airport management will ensure weekly certified payrolls are received during the grant administration process and maintained in grant files.

Contact Person: Leslie Sutera, Business Manager/Clerk Expected Completion Date of Corrective Action Plan: This corrective action plan will be completed by the end fiscal year, June 30, 2023 CORRECTIVE ACTION PLAN FINDING 2022-001: Prevailing Wage Rate Internal Control and Compliance Response: Include a clause requiring prevailing wage and weekly certified payrolls in any federal funded construction contract. Request weekly certified payrolls to correspond with invoices at the time they are received. STATUS OF PRIOR AUDIT FINDINGS FINDING 2021-001: Unrecorded Accounts Payable Response: Implemented

2022-004 SPECIAL PROVISIONS ? WAGE RATE REQUIREMENTS Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, and 84.425W Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 and S425C210015 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: ? Material Weakness in internal control over compliance CORRECTIVE ACTION PLAN (CAP): Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: Management will implement procedures and controls to obtain the necessary documentation to verify that contractors are in compliance with the wage rate requirements. Official Responsible for Ensuring CAP: Heather Hipp, Business Manager. Planned Completion Date for CAP: June 30, 2023.

The district does not agree with the finding in that a correction has been made prior to the audit. The district ensures to collect prevailing wage reports from current contractors that are paid using Federal grant funds. At this point, the only contractor being used is Gardiner for HVAC systems. The finding is from a company that sold their book of business during or immediately after the school project was completed. The company did not send prevailing wage reports to the district and the new company did not have payroll records for the company that did the project.