Corrective Action Plans

Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund– Assistance Listing No. 84.425D & 84.425C Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: See the previous corrective action plan for item2023-05. Name(s) of the contact person(s) responsible for corrective action: Brian Dasher, Director of Business Services Planned completion date for corrective action plan: 12/1/2024

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditure must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 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 for any new ARPA contracts. Most all of the 2023 expenditures were part of contracts that were already in place when the 2022 findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Sherri Crow, Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2024

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, 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. 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 March 31, 2025.

The Town and Board of Education have implemented a written policy for purchases using federal funds. This policy includes verifying that vendors have not been debarred.

The Town and the Board of Education have prepared and implemented a written policy for purchases using federal funds.

Contact Person LeAnn Littlewolf, Executive Director 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 2024

Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance. training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. These improvements will be in place by March 31, 2025. I, Timothy Jung, Interim Chief Financial Officer, will be responsible for resolving this deficiency by March 31, 2024.

CORRECTIVE ACTION PLAN (Concerning Finding 2023-007) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-007 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and drafted, has had approved, and has implemented the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024

CORRECTIVE ACTION PLAN (Concerning Finding 2023-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-004 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and is using the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024.

Environmental Protection Agency, passed through State of North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: General Manager (Vacant) and Jan Lee, Office Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements Anticipated Completion: December 31, 2024

Material Weakness in Internal Control Over Compliance and Material Noncompliance Procurement 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 reviews its procedures over federal procurements to incorporate controls to ensure the detailed history of all procurements is properly documented. Name(s) of the contact person(s) responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2024

Material Weakness in Internal Control Over Compliance and Material Noncompliance Procurement 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 reviews its procedures over federal procurements to incorporate controls to ensure the detailed history of all procurements is properly documented. Name(s) of the contact person(s) responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2024

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

Management agrees with the finding. Management has drafted a procurement policy, and will enact and enforce this policy by the end of 2024. This policy will be reviewed annually to ensure that any changes in laws and regulation are reflected in internal procedures.

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: Action steps Who At least quarterly program level review of budget vs. actuals to discuss trends, variances, potential errors in coding of transaction Finance Team and Executive Directors At least quarterly review of admin costs, to review for trends against budget and errors in classification of transactions Finance Team and Executive Directors Adjust cadence /deadlines for balance sheet reconciliations and incorporate Finance Director level review. Ensure adjustments are made in a timely manner. Finance Team Email weekly cash deposit report for Executive Directors and Finance Director to review for proper classification in the general ledger Finance Team and Executive Directors Streamline key processes which will allow finance team the time and flexibility to analyze and strategize and get ahead of firedrills; this will allow them to understand the story that the numbers are telling. Finance Team Continue to document procedures. This will ensure proper backup when team members are out due to vacation or illness. Comprehensive, documented procedures are the teams bench strength. Finance Team Ensure all transaction in the general ledger have proper backup to ensure understanding of underlying transaction Finance Team Anticipated Completion Date: End of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard and Tara Moss, Co-Executive Directors

Finding Number 2023-002 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: ULMS’s policy on procurement outlines the process and documentation required to select vendors for contracts over the micro-purchase threshold. The policy was followed, but documentation could not be retrieved as it was not submitted to accounting and some of the decision makers of the contract are no longer with ULMS. Management recognized this issue and created a procurement form that streamlines the selection, justification and documentation of the process in March 2024 which was before the organization was informed of this finding. Additionally, management transitioned the form online in August 2024 and a copy of the completed form is automatically sent to ULMS’s procurement email. Management also provided procurement training to all employees involved in the procurement process. Anticipated Completion Date: Date completed 3/19/2024

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 day-to-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

Auditee Response: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to when applicable. Corrective Action Plan: (1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Lane Mecham, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract – November 2023 Certified weekly payroll reports obtained from contractor – November 2023

Contact Person Responsible for Corrective Acton Plan: Debbie Nelson County Auditor. 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 2 of our 2 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2024

We value your guidance and are committed to enhancing our compliance with the Uniform Guidance. In response, we will: 1. Documentation Procedures: We will implement procedures to properly document procurement activities. This will help us maintain consistency and ensure compliance with the Uniform Guidance. 2. Monitoring and Accountability: Additionally, we will establish a system to regularly monitor our compliance with these policies and procedures. This will enable us to quickly address any issues that may arise. The Finance Department will be responsible for implementing these changes and will have everything ready before the end of 2024. We are dedicated to making these improvements and truly value your support as we work through this process. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024

We understand how crucial it is to have strong policies and procedures in place. Here’s how we plan to move forward: 1. Review of Existing Policies and Procedures: We’re currently taking a close look at our existing policies and procedures to ensure they align with the Uniform Guidance. This will help us identify any gaps and make necessary updates so that we’re fully compliant. 2. Development of New Policies: Alongside this review, we will create clear and comprehensive written policies in key areas, such as: • Cash Management: Setting up procedures that comply with 2 CFR 200.305 to ensure timely payments. eCFR :: 2 CFR 200.305 -- Federal payment. • Allowability of Costs: Crafting guidelines that follow Subpart E—Cost Principles, so we can confidently determine which expenses are allowable. https://www.ecfr.gov/current/title-48/chapter-7/subchapter-E/part-731/subpart-731.7/section-731.770. • Conflict of Interest: Establishing standards of conduct that address potential conflicts and promote transparency. • Equipment and Real Property Management: Developing policies for managing equipment acquired under federal awards in line with 2 CFR 200.313(b). eCFR :: 2 CFR 200.313 -- Equipment. • Procurement Procedures: Creating clear procurement guidelines that align with 2 CFR 200.318 through 200.326 to ensure fairness and oversight. eCFR :: 2 CFR 200.318 -- General procurement standards. 3. Training and Communication: The Finance Department will be responsible for training all staff involved in managing federal awards. Training sessions will ensure that everyone understands the requirements and their roles in maintaining compliance. This training will be completed by December 31, 2024. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024

In responding to the findings of the audit regarding the absence of a documented procurement policy that aligns with federal statutes and procurement requirements as outlined in 2 CFR Part 200, Sigma Beta Xi, Inc. acknowledges the criticality of this oversight. We understand the importance of having formal, documented policies in place to guide our procurement processes, ensuring they are transparent, equitable, and in full compliance with federal regulations. The absence of such documentation represents a missed opportunity for our organization to institutionalize best practices and safeguard the integrity of our procurement activities. Corrective Actions and Commitments: Please let it be known prior to completion of our 2023 audit we were still in the process of finalizing our 2022 audit. Therefore, it was not a matter of willful intention in not being compliant with the Federal mandated guidance policy for Procurement and Suspension and Debarment, but a matter of timing. Research of our vendors was in the process for 2023, but documentation of the research was not being recorded. To address this finding and prevent future occurrences, Sigma Beta Xi, Inc. has taken the following steps: 1. Policy Development: We are in the process of developing a comprehensive procurement policy that will be fully documented and accessible. This policy will outline the procedures for all procurement activities, ensuring they are consistent with the requirements set forth in 2 CFR sections 200.318 through 200.326. It will reflect applicable state and local laws and regulations, as well as conform to applicable federal statutes and procurement requirements. 2. Stakeholder Engagement: Recognizing the importance of stakeholder buy-in, we will involve key personnel from various departments in the development of the procurement policy. This collaborative approach ensures the policy is comprehensive, practical, and adheres to the diverse needs of our organization while maintaining compliance with federal regulations. 3. Training and Implementation: Upon completion and approval of the procurement policy, we will conduct training sessions for all relevant staff. These sessions will cover the details of the policy, emphasizing the importance of compliance with federal statutes and the procurement requirements identified in 2 CFR Part 200. This will ensure that all team members are knowledgeable about the policy and understand their roles and responsibilities within the procurement process. 4. Monitoring and Compliance: We will establish mechanisms for monitoring compliance with the new procurement policy. This includes regular audits of procurement activities and ongoing reviews of the policy to ensure it remains current with federal regulations and best practices. 5. Documentation and Transparency: All procurement activities, especially those exceeding the simplified acquisition threshold, will be thoroughly documented, including the rationale for the procurement method used, selection of contract type, contractor selection or rejection, and the basis for the contract price. This documentation will ensure transparency and accountability in our procurement processes. Sigma Beta Xi, Inc. is committed to rectifying this deficiency by not only developing and implementing a documented procurement policy but also by fostering a culture of compliance and continuous improvement. We view the audit findings as an opportunity to enhance our operational effectiveness and ensure that our procurement practices fully support our mission to break the cycle of poverty and violence through mentoring, education, and community organizing. Our dedication to upholding the highest standards of integrity and transparency in all our operations is unwavering, as we continue to empower future professional leaders in every community we serve.

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

Management agrees with the assessment and will work to develop a procurement policy.