Corrective Action Plans

Auditee?s Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001: Covid 19 ? Elementary & Secondary School Emergency Relief Find II ? Special Tests and Provisions ? Wage Rate Requirements District Response: A. The District understands the requirements outlined in the Davis-Bacon Act at this time. Any future projects will be bid with Davis-Bacon requirements in the bid documentation. B. Paige Bromen, Chief Financial Officer, will review weekly wage certification sheets and compare them to applicable wage rate determinations for future projects. Additionally, Paige Bromen, Chief Financial Officer, will be responsible for assigning and documenting interviews of contractor employees and for verifying required labor postings. C. The corrective action plan will be implemented immediately January 6, 2023. Sincerely, Paige Bromen Chief Financial Officer cc: Chris Chism, Superintendent

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

2022-006 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425C220015, S425D220045, and S425C220045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that the District consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement a policy to consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. Name of the Contact Person Responsible for Corrective Action Plan: Kate Fernholz, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2023

The Daleville City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. 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 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, Linda Harper, 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 has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective January 1, 2023, stating that the Chief School Financial Officer, Linda Harper, 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.

SINGLE AUDIT FINDINGS: Finding 2022-001: Procurement and Suspension and Debarment Description of Finding: The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence: The City concurs. Corrective Action: The City will enhance their existing policies for procurement to be in accordance with Uniform Guidance Procurement Standards and plans to be adopted by June 30, 2023. Name of Contact Person: Henry Dachowitz, Chief Financial Officer Projected Completion Date: June 30, 2023

The University will review the specified requirements of the Office of Management and Budget Guidance for Grants and Agreements with the University?s grant professionals in Finance and the Office of Sponsored Programs to recommend an appendix for federal grants expenditures to the University?s procurement policy as part of the upcoming annual review.

Department of Health and Human Services FINDING ? FEDERAL AWARD PROGRAMS AUDITS 2022-002 Policies and Procedures Material Weakness Recommendation: The Organization should adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Action Taken: The Organization adopted a ?Fiscal Policies and Procedures Manual? on October 1, 2022.

Material Noncompliance Material Weakness in Internal Control over Compliance 2022-002 Procurement and Suspension and Debarment Recommendation: Recommend the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Action taken in response to finding: 1. Review and update existing Purchasing Guidelines to conform with Uniform Guidance. 2. Revise procedures for adding new vendors, implement a check for Suspension and Debarment. 3. Recommend to Board of Selectmen a revised Procurement Policy. 4. After acceptance and approval of revised procurement policy provide training to staff on new policies and procedures surrounding procurement. Name(s) of the contact person(s) responsible for corrective action: Mandi Moore, Finance Director Planned completion date for corrective action plan: 6/30/23 If anyone has questions regarding this plan, please call Mandi Moore at 860.627.1449 option 4

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, Linda Harper, 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 has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective January 1, 2023, stating that the Chief School Financial Officer, Linda Harper, 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.

2022-005 - Finding Condition We noted during testing procurement, suspension, and debarment that the County doesn't have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan per Debbie Nelson, Auditor We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2023

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-001 Procurement Description of Finding The City is required to utilize a sealed bidding process for expenditures in excess of the $250,000 threshold per Uniform Guidance. As a result of our testing, we noted two vendors with expenditures in excess of the threshold which did not utilize the sealed bidding process. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action Corrective action will be taken to ensure the correct procurement procedures are followed. Name of Contact Person Lynn Boisvert, Director of Finance and Operations Projected Completion Date June 30, 2023

2022-001 PROCUREMENT Federal Assistance Listing Number: Higher Education Emergency Relief Fund (HEERF) 84.425F Criteria A non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The College must use its 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. Observation/Condition/Context The College did not follow its procurement policy in one identified instance out of six tested. It was noted that the College did not solicit competitive price quotations for a purchase exceeding policy thresholds under the HEERF program. Questioned Cost There were no questioned costs associated with this finding. Cause/Effect Following the established procurement policy allows for cost comparison and the ability to evaluate whether a vendor is reputable and if the contract has all the required provisions. By not following the policy, the College opens itself up to higher costs and riskier transactions. Recommendation We recommend that the College implement a review process to identify potential instances of noncompliance with the College?s procurement policy. Planned Corrective Action ? The Business Office and Purchasing teams will amend our current procurement policy to 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. ? The Business Office and Purchasing teams will work with the college?s internal Administrative Information Systems staff to implement an additional review step in the Workday requisition process for the following qualified purchasing thresholds: o Micro-purchases under $10,000 would suggest sought out competitive vendors o Small purchases over $10,000 and less than $250,000 would require quotes o Formal procurement methods for purchases over $250,000 would require sealed bids Implementation Date Beginning July 1, 2023 Responsible Personnel Jacquelyn Craddock, Purchasing Manager Contact Information Email: jcraddock@cca.edu

2022-001 Procurement, Suspension, and Debarment In accordance with2022-001 Procurement, Suspension, and Debarment In accordance with 2 CFR 200.318, management will adopt documented procurement procedures that reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. The Board adopted a procurement policy on January 12, 2023. 2 CFR 200.318, management will adopt documented procurement procedures that reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. The Board adopted a procurement policy on January 12, 2023.

2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion 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. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. Corrective Action: Effective June 15, 2022, the procurement policy will be adhered to and purchases will be adequately documented. Responsible Persons: Stephanie Vullo, Chief Compliance Officer, 718-780-0605, stephanie.vullo@brooklaw.edu; Herberth Melendez, Associate General Counsel, 718-780-7952, herberth.melendez@brooklaw.edu

The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review_vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and_Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached._At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document_from SAM.GOV verifying eligibility of vendor will be attached to the vendor file.

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity, and Security Finding Summary: The Organization’s procurement policy does not contain all provisions required by Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a price analysis over the transactions tested. Management’s Response and Corrective Action Plan: We are working to implement additional controls where policies are reviewed in depth and are current in order to ensure procurement, suspension, and debarment policies are properly complied with and documented. Responsible Individuals: Rufus Glasper, President and CEO, and Cynthia Wilson, Vice President for Learning and Chief Impact Officer Anticipated Completion Date: January 2024

We agree with this audit finding. Sallal developed, and the Board of Trustees adopted a procurement policy in December 2022 that complies with procurement standards established in 2 CFR sections 200.318 through 200.326. The procurement policy will be in place going forward.

Action Taken: The Home will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.

Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon training completion, the team will provide the Finance Committee of the Board of Directors suggested updates to our current policy.

Management Comments and Corrective Action: During the course of the single audit for the year ending August 31, 2022, it was noted that SWK "legacy" contracts did not follow the established procurement policy and procedures which requires SWK to obtain quotes from at least three sources and/or did not document the quotations in the procurement file for one expenditure between $25,000 to $100,000. This instance of noncompliance noted was for a consumer goods (i.e., clothing, and personal healthcare). Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized an existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization, hired new procurement leadership and invested Full Time Employees (FTEs) to develop a robust procurement department. As a result of this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provided tools for the selection of the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2023. Person Responsible for Corrective Action: Fred Muniz, CFO 2023

Compliance Finding The City's procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In Fiscal 2023, policies and procedures for expending federal funds were updated to include requisite review and documentation of said review during the awarding of contracts and prior to submitting invoices for approval.

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Denise Watters, CEO Anticipated Completion Date: December 2023 Planned Corrective Action: The Club will take immediate steps to strengthen its internal controls related to procurement of goods and services. This includes the revision of our written procurement standards to align them with federal regulations and guidelines. Additionally, we will establish procedures for maintaining adequate supporting documentation that demonstrates compliance with federal procurement standards. To ensure compliance with the prohibition on contracting with suspended or debarred parties, we will verify the status of entities with whom we enter into covered transactions using methods such as checking the System of Award Management (SAM) or collecting certifications. Responsible officials will oversee the plan's implementation, and we will maintain comprehensive records to demonstrate our commitment to adhering to federal procurement regulations and guidelines. This corrective action plan is vital to achieving and sustaining compliance with federal procurement standards.

Corrective Action Plan for the Calendar Year Ended December 31, 2022 In response to the finding from the Federal single audit for the fiscal year ended December 31, 2022. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2022-002 - Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will strengthen its processes and internal controls to ensure the report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards. Christopher Caulfield, Executive Director of Financial Operations, will implement the corrective action plan, which is anticipated to be completed by December 31, 2023. caulfieldc@sihmc.org 973-754-2016

Finding Reference Number: MW2021-007 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: Vendor status for 2021 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. Vendor onboarding now includes a required disbarment check conducted by the Director of Finance. In 2024, new procurement requirements were added to clarify thresholds and competitive procurement processes, and an approval certification step was implemented for all vendor payments. This monthly certification, performed by the Director of Finance or Executive Director, ensures that payment recipients are not suspended or disbarred. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete