Corrective Action Plans

The District will make sure every project abides by the prevailing wage law.

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Program: COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Assistance Listing Number (ALN): 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425F201693 Federal Award Year: June 30, 2022 Condition: The College?s policies and procedures over procurement generally conform to the requirements outlined by the Uniform Guidance with an exception bonding requirements, contracting with small and minority businesses, and items from Appendix II to Part 200. The auditors compared the College?s policies and procedures to the applicable sections of the Uniform Guidance by reviewing two vendors of a total of four vendors with expenditure for the ESF funds and obtained the associated supporting documentation for our selections. Additionally, the auditors noted that the Institution?s procedures were not followed with regard to ensuring full and open competition, obtaining bids/quotes for the items above the micro-purchase threshold, or retaining documentation for the requirement for verifying for vendor suspension or debarment prior to contracting. The College did check for suspension/disbarment following our identification of the finding and there were no issues. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Nathan Engle Controller

Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities 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. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Corrective Actions Taken or Planned: Recently we implemented and communicated a revised Procurement policy that reinstates the requirement of 3 competitive bids if the requisition amount is over $10K. NSC will ensure reinforcement of this policy through multiple layers of review (Legal, Accounting and Executives). Although, the policy was recently reinstated NSC will ensure that it will abide to the policy as much as is possible for all purchases prior to November 1st. In order to facilitate and implement the new procurement policy, NSC will utilize ERP system AVID which helps create approval routings through automated workflows. Accounting, Legal and up to the VP level will ensure and review proper documentation. The CFO and COO will be the final line of review prior to ultimate approval for all purchases above the VP delegation level of authority. The following approvals are required for procurements for items up to: 15K by VP?s of business units 50K by CFO, 100K by COO, Over $100K by CEO. A thorough review of Federal grants will be performed and a new standard operating procedure created, to ensure that all federal ruled are properly being followed as part of the procurement policy. Finally, multiple training sessions and communications to all affected staff will be conducted in order to ensure future compliance at all levels. Anticipated completion date: October 27th 2022 Individual Responsible: Ron Hausner, CFO

The City of Tracy, California respectfully submits the following corrective action plan for the reported findings for the fiscal year ended June 30, 2022. The findings are numbered consistently with numbers assigned in the June 30, 2022 Single Audit Report. Finding 2022-001 Procurement Policy Criteria: 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. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $3,500 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(c); the competitive proposals method under the conditions specified in 2 CFR section 200.320(d); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(f). Finding 2022-001 Procurement Policy (Continued) Criteria (Continued): 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(d)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR part 200, ?Contract Provisions for Non- Federal Entity Contracts Under Federal Awards.? Non-federal entities had a grace period of two full fiscal years after the effective date of the Uniform Guidance before they had to comply with the procurement requirements of 2 CFR section 200. For a non-federal entity with a fiscal year-end of June 30, its effective date for the procurement requirements was July 1, 2017. However, during this grace period, non-federal entities were required to clearly document whether they decided to comply with the previous version of the applicable procurement standards or the new standards contained in the Uniform Guidance. Condition: The City has not updated its purchasing policies and procedures to bring it into compliance with the requirements of Uniform Guidance. The City has also not formally documented whether it has decided to extend its applicable date of compliance with 2 CFR part 200 to be effective beginning July 1, 2018. Context: See condition above for context of the finding. Cause: The City has not evaluated its existing procurement policies for compliance with the requirements of the Uniform Guidance. Effect: The City is not in compliance with the procurement policy provisions of 2 CFR part 200 and the Uniform Guidance. Not updating the City?s procurement policy could lead to future findings and questioned costs related to federal awards. The current audit did not identify noncompliance with direct and material compliance requirements of the major federal award program. Identification as a Repeat Finding: Yes. 2021-001. Recommendation: The City should evaluate and update existing purchasing policies and procedures in order to bring the City into compliance with the procurement policy requirements of 2 CFR part 200 and the Uniform Guidance. The updated policy should include, among other things: Finding 2022-001 Procurement Policy (Continued) Recommendation (Continued): 1. Thresholds and appropriate approval procedures for allowable federal procurement methods. 2. Written standards for how conflicts of interest involving employees engaged to select, award, and administer contracts will be governed. 3. How to ensure that contracts and awards are made only to responsible and eligible contractors and how oversight of contractor performance will be monitored. 4. How records will be maintained in order to document the history of federal procurements. Corrective Action Plan: The City is still in the process of working with an outside firm on a review of procurement and purchasing policies. The consultation includes compliance review of this standard. Anticipated Completion date: June 1, 2023 Name of Contact Person: Sara Cowell, Interim Finance Director

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT SIGNIFICANT DEFICIENCY 2022-003: Continuum of Care Program CFDA 14.267 Grant period: Year Ended June 30, 2022 Condition and Context: The Organization does 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 that are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. 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 the Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements.

Finding #2022-002 - Major Federal Award Finding - Procurement and Suspension and Debarment. Material Weakness in Internal Controls over Compliance Corrective Action Plan: 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. A procedure will be drafted and implemented to guide managers responsible for procurement in the required procurement process based on dollar thresholds and allowable methods described in CFR 200.320. Oversight of the procurement process will be the responsibility of the EVP of Operations and the Director of Finance & Accounting.

Compliance Procedures: Operations will receive weekly Davis Bason timesheets for all contracted employees performing construction activities on federally funded projects. The timesheets must be signed by the Contractor and submitted to Millington Municipal School District. Internal Control Procedures: Finance will insure prior to making payment to the Contractor for the Applications and Certificate for Payment that all weekly Davis Bacon timesheets have been submitted to Millington Municipal Schools District for federally funded projects where construction services were done. Contact Person: Taurus Currie, CFO Proposed Completion Date: This action was completed by January 31, 2023.

This response letter is provided in connection with your audit of the financial statements of Davis and Weber Counties Canal Company, which comprise the statements of financial position as of October 31, 2022 and 2021, and the related statements of activities and cash flows for the year then ended, and the related notes to the financial statements, for the purpose of expressing an opinion as to whether the financial statements are presented fairly, in all material respects, in accordance with accounting principals generally accepted inn the United State (U.S. GAAP). Our correct action plan is to address the Federal Awards Findings, 2022-001: Written Policies - Internal Control Finding. The Company accountant, Dallen Henderson, will draft written policies to verify vendors are not debarred or suspended and will pay adequate Federal labor wages. The General Manager will present draft policies to the Board of Directors and have them passed/implemented within 90 days of this letter. Respectfully, Davis and Weber Counties Canal Company Richard D. Smith General Manager/Treasurer

2022-001: Material Weakness-Davis-Bacon Wage Rate Requirements Corrective Action: Corrective action has been taken. Management has started requiring weekly collection of payrolls from contractors for projects. These are reviewed on a weekly basis for compliance with Davis-Bacon requirements. Wage requirement clauses will be included in all contract agreements going forward. The responsibility for monitoring and reviewing certified payrolls and contracts has been assigned to the Chief of Operations or his designee. Contact Person: Anita Floyd Completion Date: December 2022

U.S. Department of Treasury 2022-003 COVID-19 State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the City 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 City 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: Alisha McAndrews Planned completion date for corrective action plan: December 31, 2023.

Corrective Action Plan The Enterprise City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS - FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 - Special Tests and Provisions - Wage Rate Requirements 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, Pam Christian, 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 will communicate with all contractors and subcontractors regarding the wage rate requirements and will implement additional procedures, effective May 1, 2023, stating that the Chief School Financial Officer, Pam Christian, will 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 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.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing/Federal CFDA #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Finding Summary: It was identified that there was no observable documentation to indicate that the required procurement or suspension and debarment procedures were performed on all vendors. Lack of oversight, awareness, or understanding of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous or to suspended or debarred vendors. We recommend that the Organization maintain the appropriate documentation evidencing that procurement and suspension and debarment procedures have been completed. Status: The procurement process is relatively new to the Organization and began during the pandemic with limited staff. The Organization has hired an additional FTE in the Business Office to assist with the management of this task. Responsibility of: Jennifer Babcock, Finance Director. Estimated Completion Date: 12/31/23

Corrective Action Plan for Current Year Finding Turning Point of Central California, Inc. submits the following corrective action plan for the identified finding for the audit period July 1, 2021 through June 30, 2022: Finding 2022-001 Procurement Corrective Action: Turning Point of Central California, Inc. has updated Procurement Policy to comply with Uniform Guidance. Turning Point of Central California, Inc. is implementing procedures to obtain and retain required documentation to conform with applicable federal statutes and procurement requirements identified in 2 CFR Part 200. Person Responsible: Finance Director David Lozano. Timing for Implementation: As soon as possible prior to be effective for the fiscal year ending 6/30/24.

Views of Responsible Officials and Planned Corrective Action: Management prepared a new written procurement policy that defines all types of purchases and is in compliance with the provisions of the Uniform Guidance. This policy was implemented on July 1, 2022.

Section III - Federal Awards Findings and Questioned Costs Compliance Requirement - Procurement, Suspension and Debarment Significant Deficiency in internal control over compliance and compliance Condition: As part of compiling the Commission's population for procurements, from which a procurement sample would be selected, the Commission identified $26,432 of expenditures charged to the grant that were erroneously included in the SEFA, as the procurement methods were not eligible for federal expenditures. As a result, prior to testing compliance related to procurement, the Commission reclassified the $26,432 of expenditures from the federal grant and removed from the SEFA as of June 30,2022. Cause: The Commission's procedures did not allow for timely identification of the expenditures prior to including on the SEFA (and claiming reimbursement). Effect: A journal entry was posted to correct current year federal revenue balance as of June 30, 2022 in the amount of $26,432. Further, the Commission has applied these expenditures to future draw downs in order to reverse the expenditures that were claimed. Recommendation: We recommend that the Commission review its closing policies and procedures as well as its federal grant management procedures to ensure procurement methods are considered prior to claiming expenditures or reporting on the SEFA. Commission Response: Staff concurs with the recommendation and has reviewed and discussed procedures with finance and transit staff. The invoices are coded for expense and funding by project managers. The reimbursement of expenditures is requested based on this information. During this time period there was a shortage of staff both in the finance and transit departments. Funding requirements were reviewed with transit staff. Finance staff will strengthen the invoice process to verify project manager coding against invoicing to prevent and if necessary, timely correct funding errors. Project Managers will be responsible for reviewing monthly project manager reports that include expenditures and associated funding reimbursed.

Corrective Action Plan for Finding IC2022-001: Financial Reporting Accomack County understands the repeat finding regarding financial reporting. In our response in FY 21 to this comment we stated ?through the addition of one FTE in the FY 23 year, staff training in particular content areas such as financial reporting, pensions and OPEB reporting, and some realignment of duties with existing staff, we are able to continue internally prepared financial reports through the year and the Annual Comprehensive Financial Report (ACFR) properly and timely?. As an update, we have not been able to make a hire at this time, and have chosen to reformat the position to non-entry level and re-advertise in the spring of 2023. While an additional resource will be helpful, existing staff understanding of timing, and year- end financial reporting will continue to be both ongoing, and a priority. Accomack County Finance continues to consider financial reporting, including the year-end annual financial report a core competency and are open to suggestions in processes or protocols that will advance our capacity and capability in this area from Brown Edwards. As part of this response, County finance recognizes we are responsible for timely and accurate reporting which includes Accomack County Public Schools (ACPS) financial information and all other component units in the ACFR. As we are currently staffed, we do not have capacity for review of ACPS financial work through the year and have previously relied on their finance department. Unfortunately, that has caused delays, findings and revisions to financial exhibits several times at year end for corrections noted by the auditors. The County will explore options for reducing the aforementioned problems and thereby improving this issue as relates the ACPS financial information. Lastly, a component of the delay in FY 22 was the Landfill Closure/Post-closure liability in conjunction with Department of Environmental Quality. We have begun a specific time-line in coordination with the Deputy Director for Public Works, who has responsibility over the landfill and south transfer station so that finance has complete and approved cost information (through the DEQ process) prior to year-end each year, or just after year-end (timely). Responsible Official: Michael T. Mason, CPA, County Administrator mmason@co.accomack.va.us (757-787-5716); estimated completion date of not later than July1, 2023 for the new hire. Corrective Action Plan for Finding FA-2022-001: Procurement Accomack County Public Schools concurs with the need to maintain its Procurement Policy in concurrence with 2 CFR Part 200. The schools will review and update procurement policies to be in compliance. Responsible Official: Chris Holland, Accomack County Public Schools Superintendent, chris.holland@accomack.k12.va.us, (757)787-5759; Estimated completion date is not later than the May, 2023 School Board meeting.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2021 ? September 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of six procurements which were tested, we noted that five of them, for which the District obtained quotes using the small purchase method, did not contain documentation detailing the history of the procurement, including any other quotes obtained. Questioned Costs: ALN 84.027 - $415,251.22. Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. 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. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of eight procurements which were tested, we noted that three of them did not have proper documentation for the justification of noncompetitive proposals and one of them the District did not have documentation detailing the history of the procurement, including any other quotes obtained due to the District not following the micro-purchase threshold listed in their policy. Questioned Costs: $58,198.49 Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. 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. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-002 Material Weakness - Davis-Bacon Act Planned Corrective Action Proper documentation not maintained by the Authority to verify compliance with Davis Bacon, due to the lack of monitoring of contractor compliance and adequate records retention by project management. A new system of checks and balance was created between Finance, Capital Project, and Procurement Departments to reconcile, evaluate, and manage construction projects on a monthly basis to ensure proper documentation and tracking. Management will add an additional requirement to include this as part of the accounts payable process. Anticipated Completion Date Complete by September 30, 2022 Responsible Contact Person Rico Owens, Senior Accountant

2022 ? 001 ALN 14.850 Public and Indian Housing ? Special Tests & Provisions ? Wage Rate Requirements The Executive Director acknowledges the findings and the Authority?s management is currently implementing the necessary changes to remediate these noncompliance instances. Person Responsible for Correction of Finding: Pauline Sturgill, Executive Director Projected Completion Date: June 30, 2023

Finding 2022-004 Procurement Suspension and Debarment Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) 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 Management agrees with this finding. Corrective Action The City has updated the policy to be in line with Uniform Guidance. Name of Contact Person Robin Stanziale Projected Completion Date January 30, 2023

CRITERIA: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients ?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? 2 CFR section 200.318(i). The Center?s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The Center also has procedures to identify procurement transactions requiring competitive bids or proposals. RECOMMENDATION: We recommend the Center ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. CORRECTIVE ACTION PLAN: The Center will review its procurement policies and internal control and ensure timely action is taken when noncompliance is identified. PERSON RESPONSIBLE: Laci Herbst, Finance Department TIMELINE: Current date through succeeding reporting period.

2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID 19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Summary of Finding: The District did not obtain certified payrolls for contractor or subcontractor work performed. The District did not have internal controls in place to identify that certified payrolls were not obtained. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. Grants Department personnel met with Facilities personnel to discuss the processes and procedures to implement, and internal controls that would ensure this. These will include a monthly checklist, verified with signatures of Facilities and Grants Department Personnel. This checklist will provide verification that certified payroll is being monitored and reviewed weekly, and is being compared to prevailing wage rates. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Initial implementation of internal controls beginning on August 1. Adjustments and revisions to initial processes as needed. The verifications are to be done on a recurring monthly basis.

2022-001 - The corrective action plan was documented in our response to the auditor's comment. See the Schedule of Findings and Questioned Costs. Mark Vasina Director of Finance 402-878-3341 June 30, 2023

The Center was unaware that, in accordance with the Department of Labor (DOL)(40 USC 3141-3144, 3146, and 3147), all laborers employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for prevailing wage rates. In the future, the Center will follow the guidance of the aforementioned section and adhere to this requirement.