Corrective Action Plans

Finding Number: 2024-001 Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Contact Person: Jeremy Bow, Director of Finance Anticipated Completion Date: August 12, 2024 Planned Corrective Action: In May of 2020, amid the urgent health and safety impacts of the global Covid-19 pandemic, Emerge closed its emergency shelter facility in order to transition to the use of a hotel to provide a non-congregate shelter setting for its Participants. In the urgency to make the transition and the uncertainty of the duration of stay, Emerge did not perform a SAM.gov review of the hotel for suspension or debarment, as federal funds were not anticipated to be utilized at the time. In April 2022, Emerge surpassed the $25,000 threshold for federal funds paid to this vendor during a fiscal year. Having previously been operating out of the hotel for nearly 2 years prior, the need for a SAM.gov review was overlooked at that time and was not identified on the audits for either fiscal year 2022 or 2023. When notified of the deficiency on August 12, 2024, during initial field work for the audit of fiscal year 2024, Emerge took same-day action to resolve the previous oversight. On August 12, 2024 Emerge performed the necessary check via SAM.gov and confirmed the vendor hotel was free from suspension or debarment. Concurrently, Emerge revised its Procurement Policy to specifically require compliance with Federal Acquisition Regulation Systems - 2 CFR §180.300 & §180.995. Per Emerge Procurement Policy, revised August 2024: “Any Agency procurement action which will utilize federal or sub-federal funds, in full or in part, shall be done so in compliance with Federal Acquisition Regulation Systems - 48 CFR §2 Subpart 2.1, 2 CFR §200 Subpart D, and 2 CFR §180.300 & §180.995 as required by federal regulation. Compliance with this and all other Federal guidance shall be the shared responsibility of the Chief Executive Officer, Senior Leadership, and the Director of Finance. Copies of these regulations shall be maintained by the Agency for reference.” It is Emerge’s perspective that appropriate action has been taken in order to substantially mitigate the risk of recurrence based on the revisions to its Procurement Policy and the internal reviews of both the revised policy and the audit finding with Senior Leadership.

The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.

2024‐001 Procurement and Suspension and Debarment Person Responsible for Corrective Action: Lark Reynolds, Business Administrator Correction Action Planned: (1) The District management will review procurement policies with staff. (2) Timely action will be taken to solicit bids for contracts that exceeds District thresholds. (3) To ensure full and open competition takes place, management will routinely review spending reports. Anticipate Completion Date: November 30, 2024

The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District will work with the contractor to obtain and review the certified payrolls to determine the contractor is in compliance.

Child Nutrition Cluster - Assistance Listing Nos. 10.553, 10.555, 10.559 Recommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review the Sole Soure form on an annual basis to make sure the form has not expired. Name(s) of the contact person(s) responsible for corrective action: Debrah Jones, Director of Strategic Sourcing and Contract Management (SSCM) Planned completion date for corrective action plan: 12/31/2024

2024‐001 Special Tests and Provision – Wage Rate Requirements Person Responsible for Corrective Action: Jeff Barben, Business Administrator Correction Action Planned: The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable. Anticipate Completion Date: November 30, 2024

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding streams are blended. The district has already started communication to relay that federal prevailing wage rates should have been utilized. Responsible Person: Nicole Eilola, Shared Services Business Manager & Stacy Price, Superintendent. Anticipated Completion Date: Immediate

Management response/corrective action plan: Efficiency Maine has delegated a staff person to work with outside counsel to revise our procurement policy as it relates to federal funds in order to properly address all requirements of the Uniform Guidance.

October 17, 2024 Cognizant or Oversight Agency for Audit: Department of Elementary and Secondary Education (DESE) Worcester Cuftural Academy Charter Public School respectfully submits the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA, 01581 Audit period: July 1, 2023 through June 30,2024. The findings from the October 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2024-001 Massachusetts Teachers’ Retirement System (MERS) Enrollment. Recommendation: Management should ensue that proper controls are in place and operating effectively to ensure that that all MTRS eligible employees are fully enrolled within thirty days of their start date. We recommend management add enrollment of MTRS for eligible employees to its onboarding checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-002 Massachusetts Teachers’ Retirement Board (MTRB) Remittances Recommendation: Management should ensure that proper controls are in place and operating effectively to ensure all MTRS payroll withholdings are remitted timely. We recommend management add MTRB remittances to its monthly closing checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-003 Written Procurement Policy Recommendation: Management revise their poiicy to comply with current standards under the Uniform Guidance. Action Token: We concur with the recommendation, and it will be implemented effective January 1, 2025. If the Department of Elementary and Secondary Education (DESE) has questions regarding this plan, please call Erika Browning, 508-347-0252. Sincerely yours, Signature: Title: Tina Krasnecky, VP of Finance

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.

Reference Number: 2023-05 Finding Type: Significant Deficiency in Internal Control Over Compliance Description of Finding: The Organization did not follow required procurement procedures for subrecipient transactions. Though a procurement policy exists for the Organization, there was no enforcement of this policy for the federal program. Failure to follow a formal procurement policy causes the Organization to be out of compliance with Uniform Guidance and/or grant requirements and increases the likelihood of disallowance of costs. Statement of Concurrence: Management agrees with the finding, however the subrecipient was formally designated budget for the federal program by the pass-through grantor which is why a formal procurement process was not followed. The subrecipient received the same allocated federal funds for the same services provided in the prior year. Corrective Action: The Organization will review internal policies and procedures and ensure that it follows procurement practice for subrecipients under 2 CFR Sections 200.318 – 200.326. Completion Date: March 31, 2026 Name of Contact Person: Maureen Thomas Chief Financial Officer 917-405-7185 maureen@frfive.org

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Procurement documentation did not consistently evidence compliance with internal policy and 2 CFR §§200.318–200.326. Status: Corrective Action Taken Corrective action planned: Voices of Tomorrow will implement procurement software to automate workflows and approval processes for procurement purchases. Voices of Tomorrow will • Revise and formalize procurement policy to align fully with Uniform Guidance requirements.Implement a standardized procurement documentation checklist requiring evidence of procurement method, cost/price analysis, and approvals. • Require CFO pre-approval for federally funded procurements above established thresholds. • Conduct staff training on federal procurement standards. • Implement quarterly internal procurement compliance reviews. Anticipated completion date: April 2026: Policy revision and training completed within 60 days; quarterly reviews beginning next fiscal quarter.

RMIPA will strictly enforce contractors to submit wage-rate compliance documentation as a condition for invoice payment. This reporting requirement will be formally integrated into contract oversight practices.

Corrective Actions Planned To address the deficiency in internal controls over compliance with respect to procurement, CHC will implement the following corrective actions: CHC will develop and implement a written procurement policy that conforms to the Uniform Guidance.; CHC will ensure sta􀀁 receive adequate training on the procurement policy and the required methods of procurement to be made when making procurements with federal awards. Responsible Person(s): CHC President, Rob Dibble as Primary; CHC Vice President Betsy Gordon as Backup Corrective Action Plan Dates: Schedule implementation starts: February 1, 2026; Staff training starts: March 1, 2026; Review process in effect starts: April 1, 2026

The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

The City will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Vendor status for 2023 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. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Action taken in response to finding: BMLT’s Board of Directors adopted a written procurement policy at its July 26, 2025, Board meeting.

Finding 2023-001 - Special Tests and Provisions: Wage Rate Requirements Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: Wage rate clauses will be included in all federally funded construction contracts. Contractors and subcontractors will be notified in writing of prevailing wage requirements, and certified payrolls will be required and reviewed for all weeks for which construction work is performed. Anticipated Completion Date: October 1, 2025

This has been corrected with the new management. We have updated our poticies to have more oversight over procurement requirements and ensure we are getting the best prices or terms for the goods and services we purchase.

U.S. Department of Transportation Highway Planning and Construction Assistance Listing Number: 20.205 Passed Through Minnesota Department of Transportation Pass Through Number: 1918265, 1920180, 1921048, 1921136, 1922210, 1920091, 1920071, 1920134, FLAP043 Award Period: 2023 Recommendation: We recommend the County implement internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will implement internal control procedures to review certification of payrolls, even when performed by external consultant. Name of the contact person responsible for corrective action: Todd Howard, Assistant County Engineer Planned completion date for corrective action plan: December 31, 2024

Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the Board of Education plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Statement of Concurrence or Nonconcurrence The City Board of Education concurs. Corrective Action management will review and enhance the procedures over the procurement and purchasing process, to be sure that all federal grant expenditures and contracts with vendors are performed properly in accordance with the Uniform Guidance. Name of Contact Person Natalie Forbes, Business Manager Projected Completion Date 6/30/2025

Finding 2023-003 – 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. Condition: During fiscal year 2023, the Town could not provide evidence that they complied with the required procurement policies and procedures in place as it related to two of the expenses charged to the major program. Context: The Town purchased a new boiler for the School however the procurement documentation could not be located and the employee who would have overseen the project was unavailable to provide the supporting documentation. In addition, the Town could not locate or provide evidence that procurement procedures were followed when selecting an engineer for the Water Tank project. Questioned Costs: $71,500 related to the School Boiler Project and $170,163.70 related to the Water Tank Project. Cause: Directors used the Massachusetts procurement guidelines and not federal guidelines. Effect or Potential Effect: There is a risk that the amount charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: The Town of Hopedale should address the noncompliance and material weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: Kelly Grant, Assistant Town Administrator Estimated Completion Date: on going as grant and funds are still being used Action Taken: one person only responsible for making sure all federal and state procurement guidelines are met and followed.

Finding 2023-001 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs 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 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. 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 2023, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds. Questioned Costs: Unkown Cause: A Town State/Federal grants procedures manual that included proper procurement procedures did not exist until February 2023. Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable. Identification as a Repeat Finding: Yes, finding number 2022-002 Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Managements Response: We acknowledge the audit finding related to non-compliance with the required procurement policies and procedures for procurements exceeding the State and Federal thresholds during Fiscal Year 2023. The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326. We are pleased to report that we believe to have addressed this issue in Fiscal Year 2024 to ensure compliance with the procurement policies and procedures, as required by both State and Federal threshold. Responsible for Corrective Plan: School Business Manager Estimated Completion Date: Fiscal Year 2024 Action Taken: The Town and Schools have adopted Acushnet’s Federal Grant Procedures Manual (February 2023). This manual ensures that all procurements are conducted in accordance with the relevant Federal and State procurement standards, specifically the requirements outlined in 2 CFR sections 200.318 through 200.326. We are pleased to report that we have taken steps to address this issue and believe we have successfully ensured compliance with these procurement policies and procedures.