Corrective Action Plans

Corrective Action Plan We are in the process of updating the Organization’s procurement policy and procedures regarding suspension and debarment requirements. Completion Date Fiscal year end 2025

Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2025

SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

Management’s Response: North Nelson Water District has made every effort to comply with purchasing requirements. In addition to these efforts, North Nelson Water District will be adopting a formal procurement policy.

Identifying Number: SA 2024-002 Description of Finding: During the audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, "Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval". During the audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During the audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred were performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Corrective Actions Taken or Planned: We are in the process of updating our Procurement Policy. We will ensure that we follow these updated policies and procedures to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

Management has developed a policy and checklist to maintain written documentation of vendor selectin and procurement process, along with the review and approved process required under the Uniform Guidance requirements.

2024-003 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City will further strengthen its internal controls to ensure timely reviews of certified payroll submissions are performed. This will include procedures to ensure that the information provided to the City by its consultant project manager is accurate. Additionally, ensure that the contractors and subcontractors submit the required certified payroll in a timely manner and in case of delinquencies, appropriate actions are taken. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Vear: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions -Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City will further strengthen its internal controls to ensure timely reviews of certified payroll submissions are performed. This will include procedures to ensure that the information provided to the City by its consultant project manager is accurate. Additionally, ensure that the contractors and subcontractors submit the required certified payroll in a timely manner and in case of delinquencies, appropriate actions are taken. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

Finding Reference 2024-03 Corrective Action Plan: All personnel involved in the administration of programs that expend federal funds, including contractors and subcontractors, will receive adequate training on Davis-Bacon Act requirements and payroll certification processes. Responsible: Eng. Maria Ayala Rivera, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2025.

Due to going out twice with this RFP during FY23/24 in order to try and receive more sealed bids the contract did not get awarded until July 1, 2024 falling into the FY24/25.

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Develop and Implement a Formal Procurement Policy o A written procurement policy will be developed that aligns with 2 CFR 200.317 - 200.327, ensuring compliance with federal, state, and local regulations. 2. Enhance Internal Controls for Procurement Compliance o All procurement transactions will be reviewed and approved by designated personnel to verify compliance before finalizing agreements. o A procurement checklist will be used for each transaction to ensure that required documentation is maintained. 3. Mandatory Suspension and Debarment Verification o The Organization will implement procedures to verify all vendors against the System for Award Management (SAM.gov) database before entering into contracts. o Documentation of suspension and debarment searches will be retained in the procurement files. Anticipated Completion Date September 30, 2025

Finding Number: 2024‐004 Program Name/Assistance Listing Titles: Indian School Equalization; Indian School Student Transportation Assistance Listing Numbers: 15.042, 15.044 Contact Person: Aurelia Tapaha, Business Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2025 Planned Corrective Action: The School will revisit financial policies and procedures and strictly comply with procurement processes. There are specific requirements for different amounts of purchases. The School will review requisitions and ask for required documents before processing. Repeat finding due to employee’s not following the procurement processes and business office personnel accepting requisitions without proper documentation attached.

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

The Department of Public Works, will incorporate the Federal Statement of Compliance form (C-56) within the Technical Specifications section of all federally-funded VDOT project contracts.

Finding 2024-001 Written Procurement Polley- This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 10.555 National School Lunch Program (Child Nutrition Cluster) funded by the Commonwealth of Massachusetts Department of Elementary and Secondary Education (DESE). Nurtury should revise its procurement policy to comply with Uniform Guidance requirements and implement policies and procedures to search for suspended or debarred vendors on Sam.gov. Fiscal Year 2025. Procurement policy is in accordance with Uniform Guidance requirements. Management and the finance committee of the board will ensure that revised procurement policies are in accordance with Uniform Guidance requirements. Tubi Olatubosun, V.P. of Finance

Finding 2024-004 US Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds Finding Summary: Both of these two deficiencies will be dealt with through an updated procurement policy as well as a check list to ensure contracts comply with all federal guidelines. In addition, all processes needed to ensure compliance will be updated or created as needed. This recommendation has been partially implemented. The procurement policy has been updated and the processes are currently under review to be completed prior to 7/31/2025.

Finding 2024-003 US Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds Finding Summary: Both of these two deficiencies will be dealt with through an updated procurement policy as well as a check list to ensure contracts comply with all federal guidelines. In addition, all processes needed to ensure compliance will be updated or created as needed. This recommendation has been partially implemented. The procurement policy has been updated and the processes are currently under review to be completed prior to 7/31/2025.

The District has created a standard operating procedure document to follow for all construction projects. The District will also share that document with all contractors to help communicate the needs of the District regarding construction projects. If necessary, the District will provide the contractor with training to make sure all payrolls are properly certified and in compliance with applicable law. The District will also create a shared Google document for each construction project to manage the progress and payments.

Name of contact person and title: Deepak Butani, CFO Response: The Organization has engaged a professional services firm in a consulting engagement to review and assist in revising their procurement policy to align its policies and procedures for procurement with Uniform Guidance. Anticipated completion date: 6/30/2025

Corrective Action Plan Finding 2024-001 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 School’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The School also has procedures to identify procurement transactions requiring competitive bids or proposals. Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Dane Roberts, Executive Director and Randi Limb, Business Manager Timeline: All future contract solicitations will follow the required procurement standards.

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager and Project Manager 2. Corrective action planned: Grants Manager will work in conjunction with the Project Manager to ensure the following when federal monies are used for construction projects: ● Determine the project will exceed $2,000 and will qualify under Davis-Bacon-Act ● Confirm the prevailing wage and include it in each solicitation to contractors ● Notify contractors that Davis-Bacon-Act must be followed at the time of reaching out for a project bid ● Collect and file weekly payroll statements from the contractor until the project is finished ● Include assurances in federal projects that Davis-Bacon-Act was followed ● Report all suspected or reported violations to the Federal awarding agency 3. Anticipated completion date: July 1, 2025.

This is the result of a contract that was signed for engineering work on the Grass Valley Nitrate Mitigation project. Individuals involved in the procurement process incorrectly relied on NRS requirements governing professional services contracts and did not go out to bid for the services. Additionally, Humboldt County serves as the financial processor for the Humboldt River Basin Water Authority Advisory Board. The HRBWA received grant funds for the water right relinquishment program through the State of Nevada Division of Water Resources. The County will enhance communication with the executive director of the HRBWA to ensure that all procurement processes are followed and documented.

Finding 2024-001 Federal Department: Department of Labor Assistance Listing #: 17.274 Material Weakness in Internal Controls and Noncompliance Category of Finding – Procurement, Suspension, and Debarment Finding Summary: There was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Responsible Individuals: Jill Johnson, Executive Director Corrective Action Plan: Our Executive Director and Controller developed an updated procurement policy. This policy went into effect on July 1, 2024 and has been implemented throughout the organizational system. Anticipated Completion Date: July 1, 2024

Finding 2024-002 Procurement and Suspension and Debarment (Compliance) – 2020 Findings Major Federal Award Programs Condition The City's procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Corrective Action Plan The City issued and updated purchasing policy which includes the CFR requirements in early fiscal year 2024-2025. The city has hired adequate staffing which allows the purchasing department to enforce the suspension and debarment process during the procurement process. The City will have a formal process to require checking for Procurement and Suspension and Debarment prior to any contracts being issued. The policy will include but not limited to: 1. Bidding/RFP requirements: Prior to making a grant-related purchase, the procurement office will check the selected vendor on www.sam.gov prior to approving. The procurement office will document the Suspension and Debarment verification by including a screen print of the Exclusions search. 2. Annual check Annually, procurement will run a list of all vendors and employees paid from federal funds. This list will be reviewed against sam.gov, unless set up one month prior to the review. 3. Notification in bid/RFP specifications The procurement office will also make sure to include language in the specification about complying with CFR rules for federal funding. The implementation of this recommendation is monitored by the Procurement Director and Finance Director Michael Gormany or designee.

2024-001 (Procurement and Suspension & Debarment) Management Comments and Corrective Action: 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 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 to those vendors playing an important role in the Organization’s dayto- day operations. In April 2021, the Organization hired new procurement leadership and invested in Full Time Employees (FTEs) to develop a robust procurement department. Due to 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 provide tools for selecting 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, 2025. Person Responsible for Corrective Action: Steven Beckman, CFO 45