Corrective Action Plans

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.

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