Corrective Action Plans

The District is in the process of reviewing its procurement practices and intends to implement a formal policy in alignment with state and federal requirements. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

The District is in the process of reviewing its procurement practices and intends to implement a formal policy in alignment with state and federal requirements. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: Mandatory documentation of quotes for applicable procurements Verification and documentation of suspension and debarment checks for all covered transactions Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.

2024-003 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not follow their documented procurement procedures for approving one contractor. Corrective Action Plan: All procurement procedures will be followed as documented in YWCA St. Joseph financial policies. Person(s) Responsible for Implementation: Danielle Brown, CEO, dbrown@ywcasj.org, 816-232-4481

Management’s Response: The School Board will take the appropriate action to ensure that all federally funded current and future contracts contain the required clauses and provisions as outlined by 2 C.F.R. § 200.326 and 2 C.F.R. Part 200, Appendix II. Additionally, the School Board will ensure that all appropriate affidavits are included as required by L.R.S. 38:2224, for public works contracts. This includes assistance provided by outside consultants and further training to ensure that staff responsible for federally funded contracts understand all requirements to be included. Katherine Phelan, Chief Financial Officer, will be responsible for implementing this corrective action plan and the School Board anticipates completion of this corrective action by March 2025.

The Organization will document a procurement policy to ensure it fully complies with the Uniform Guidance requirements.

Management will continue strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. Purchase orders will no longer be included in any submissions. 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 and that all relevant documentation will be retained.

Finding 2024-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program 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. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, a deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2024, the Town did not comply with the required procurement policies and procedures in place as it related to expenses charged to the major program requiring procurement procedures. One of the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78 Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2023-003 Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: CFO Estimated Completion Date: January 2025 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

IBBG will develop and adopt a written procurement policy that is consistent with the Uniform Guidance, 2 CFR §§200.318–200.326, and applicable state and local laws. The policy will outline procurement methods, competitive bidding requirements, conflicts of interest, and documentation standards. In addition: • A draft policy will be prepared by the I Be Black Girl leadership, the finance committee, and D&K Financial LLC. • The Board of Directors will adopt the final policy. • Training will be provided to staff involved in procurement to ensure consistent implementation of the procurement process.

Management Response: The Organization will establish a procurement policy in 2025. Anticipated Completion Date: 12/31/2025 Responsible Party: Board of Directors

United States Department of Agriculture Federal Assistance Listing #10.855 Distance Learning and Telemedicine Grants United Stated Department of Treasury Federal Assistance Listing #21.029 COVID-19 Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Finding Summary: During the course of the engagement, it was identified that the Cooperative does not have a written policy that addresses the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Mark Vosacek Finance Manager Corrective Action Plan: The Cooperative will modify its written procurement policy 322 to include the requirements of 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: December 31, 2025

Professional and Cultural Exchange Programs - Citizen Exchanges - Assistance Listing No. 19.415 Recommendation: We recommend that the Foundation review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: American Institute For Foreign Study Foundation, Inc. does not agree with the finding. During a visit by representatives of BEGA the existing procurement policy was shared with those representatives. They approved of it and did not recommend any changes. However, a compliant policy that complies with CFR sections 200.318 through 200.326 will be developed. Name of the contact person responsible for corrective action: James Mahoney, CFO Planned completion date for corrective action plan: August 31, 2025

2024-005 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: There is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and have taken steps to strengthen compliance with procurement policies. We have established additional documentation requirements for all procurements, ensuring that each transaction clearly reflects adherence to policy, including vendor selection rationale and approval workflows. Procurement policies are being updated to incorporate explicit internal controls and approval processes. Staff involved in procurement will receive guidance on these updated requirements. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2025

Contact Person – Pattie Solberg, City Auditor Corrective Action Plan – The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date – December 1, 2025

Management’s Response: The Association will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.

Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2024 COVID-19 - Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material NoncomplianceFinding Summary: During the course of the engagement, it was identified that the Cooperative's written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative did not follow procurement, suspension, and debarment procedures required under the Uniform Guidance prior to entering into contracts with vendors. Responsible Individuals: Director of Administration Services, General Manager Corrective Action Plan: The Cooperative will update its Board Policy No. 205 to include the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative will maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2025

2024-002: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School's reasoning for a noncompetitive procurement. Repeat Finding: Similar to prior year finding 2023-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Finding 2024-002 Corrective Action: We will update our procurement policies and procedures to align with the latest Uniform Guidance requirements, including the 2024 updates that mandate documentation of price reasonableness for all micro-purchases. We plan to adopt a standardized coding submission that clearly articulates the various types of purchases and the appropriate documentatoin for each type of purchase. We will adopt regular training sessions for procurement and grant management staff to reinforce comnpliance requirements and proper documentation practices. Person Responsible: Interim CFO - Bruce Tyler and Finance Director - Jason Phillips Timing for Implementation: October 31, 2025

Person responsible for this corrective action plan: Jana Kent, Executive Director Corrective Action Plan: YNHA is developing a suspension and debarment training for all staff and program managers to ensure that suspension and debarment requirements are adhered to and include a search on Sam.gov, as required. Estimated Completion Date: October 31, 2025

Contact Person (s): Jim McCarthy - jim@waterwatch.org ; Neil Brandt – neil@waterwatch.org Corrective actions planned: The following corrective actions are being immediately implemented for contracts in WaterWatch’s restoration program in order to achieve compliance: 1. Language requiring all contractors to comply with the Build America, Buy America (BABA) Act is added to all new WaterWatch contracts and all current contracts via amendment. 2. Language requiring all contractors to comply with federal suspension and debarment contracting standards is added to all new WaterWatch contracts and all current contracts via amendment. 3. WaterWatch will keep formal documentation of debarment searches for all contractors. 4. WaterWatch will keep formal documentation of contractor procurement process in both Southern Oregon and Portland offices. Anticipated completion date: September 1, 2025

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA adopted a new, updated procurement policy in October 2024. PDA worked with Clark Nuber to develop this policy. Anticipated Completion Date: October of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors

Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: The City does not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Finance Officer Corrective Action Plan: The City will establish controls to follow all applicable procurement requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: December 31, 2025

The Organization is in the process of revising its procurement and conflict of interest policies to ensure alignment with the requirements of 2 CFR §§ 200.318 through 200.326. During fiscal year 2026, the Organization will adopt updated written procedures and implement a formal internal control checklist to verify compliance with federal procurement standards across all grant-funded purchases. Staff responsible for procurement will receive training on the revised policies to ensure consistent application moving forward.

Corrective Action Plan: During Q4 2025, Shiloh’s general purchasing policy will be updated to consider the requirements included in 2 CFR 200.328 through 200.326. (Note: This update was originally to be implemented in Q4 2024 but was delayed due to unexpected turnover in the Business Department.)