Corrective Action Plans

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control and Compliance According to the USDA-RD, the Tongue River Valley Joint Powers Board/The Tongue River Gas distribution project is exempt from being compliant with the Davis Bacon Labor Laws. Therefore, the Board believes this finding is not applicable. The bidding and bonding process for the construction of the Natural Gas Distribution system complied with all Federal Regulations. The current activities are funded by user fee which are in part used to make loan payments.

Corrective Action Plan: The Corporation has reviewed the current procurement standards and has identified gaps in compliance with the federal requirements. To address this, the Corporation will adopt a Procurement Policy Addendum, based on the attached draft, which includes compliance measures for: ● Small and minority business engagement ● Domestic preferences for procurements ● Recovered materials procurement ● Cost analysis for contracts over the Simplified Acquisition Threshold ● Bonding requirements for construction contracts ● Contract provisions regarding Equal Employment Opportunity, Davis-Bacon Act, and other federal mandates The attached model policy will be presented to the Board for formal adoption and will be incorporated into the Corporation's procurement procedures to ensure full compliance with 2 CFR § 200.318-326. Responsible Individual: Joseph Ninomiya - Chief Executive Officer Planned Date of Implementation: October 23, 2024

Corrective Action Plan: A new Procurement policy is currently being drafted and will be approved prior to October 31, 2024. This will include update to policies to align with Shiloh’s general purchasing policy and updated to include requirements identifies in 2 CFR 200.318 through 200.326. Individual responsible for corrective action plan: Steven Ramirez

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No documented procurement procedures Statement of Concurrence or Nonconcurrence: The Borough of Sharpsville agrees with the finding in Borough of Sharpsville 2023 Single Audit Report Schedule of Findings. Corrective Action: The borough will revise its outdated procurement policy to comply with all state and federal programs which meet uniform guidance. Name of Contact Person: Kenneth P. Robertson, Borough Manager-Secretary/Treasurer (724) 962-7896 krobertson@sharpsville.org Projected Completion Date: Borough of Sharpsville anticipates resolving the audit finding by resolution of borough council at its November 2024 meeting. Any questions or concerns should be directed to Kenneth Robertson at (724) 962-7896. Sincerely yours, Kenneth P. Robertson Borough Manager-Secretary/Treasurer

Finding 2023-003 – Procurement Non-Compliance (Material Weakness) Federal Program Title: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Assistance Listing Number: Various Action taken in response to finding: We have taken steps to identify all active federal awards that are subject to Federal procurement requirements under 2 CFR Part 200; these actions will ensure that all purchase orders and other subcontract arrangements under existing federal awards are subject to our purchasing system policies and procedures for Federal awards. Southern Research’s existing purchasing policies and procedures for Federal awards were reviewed and deemed acceptable in 2017 by the Defense Contract Management Agency (DCMA) Huntsville, AL. Contracts appropriately classified as Federal awards will be subject to purchasing policies and procedures that are compliant with Federal regulations. As part of the business process review, we will implement processes to ensure that all new Federal awards are classified correctly, and that Southern Research’s Federal purchasing system policies and procedures are applied to all Federal awards. Name of Person Responsible for the Corrective Action Plan: David A. Rutledge, Sr. Advisor - Finance Planned Completion Date for Corrective Action Plan: We anticipate that new process recommendations from the business process review related to purchasing will be implemented no later than December 31, 2024.

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 the following actions have been taken to improve the situation. We hired a Contracts & Compliance Manager in 2024 who is now responsible for ensuring the procurement process is properly documented for each procurement made. 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, 2024

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review and modify the procurement policy and conflict of interest policy and make all necessary changes for compliance. Name of the contact person responsible for corrective action: Michael Riso, CFO Planned completion date for corrective action plan: June 30, 2024

Management’s response and corrective action is as follows: Purchasing Department has implemented the following corrective actions to avoid this in the future: requisition checklist outlining guideline for compliance; creating standard operating procedure for purchase of vehicles for City-Parish Agencies; conduct routine departmental training; ensure that supervisor approvals prior to bid release. Expected Implementation Date: June 2024 Contact person: Paul Narcisse, Purchasing Director, Office of Purchasing

Management will 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. 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 and that all relevant documentation will be retained. Christopher Caulfield, Executive Director of Financial Operations, will effectuate the corrective action plan, which is anticipated to be completed by December 31, 2024. caulfieldc@sjhmc.org 973-754-2016

Contact Person - Pattie Solberg, 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, 2024.

2023-002 Special Provisions U.S. Department of Education Impact Aid – Assistance Listing No. 84.041 Pass-Through Agency: N/A Pass-Through Number(s): N/A Recommendation: The District should refine its current process and associated controls surrounding the requirements in 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address the finding, the district procurement process will be updated to include steps to contact vendors/contractors about their prevailing wage rate requirements on all contracts paid from federal funds. In addition, the district will request vendors to submit Form WH-347 at the conclusion of all federally funded projects. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer. Planned completion date for corrective action plan: December 31, 2024

The Organization agrees with the recommendation. The procurement policy was updated in August 2024 with all the elements required by the UG.

District will ensure compliance by prevailing wage documentation will be provided to the district with the original pay app request.

The award subject to this finding was a novel award for Texas Biomed and, therefore, controls relative to the wage rate requirements were not in place. Texas Biomed relied on the general contractor awarded the construction project to facilitate compliance with the special tests and provisions; however, failed to validate that certified payrolls were provided as required. Texas Biomed has since implemented enhanced procedures and controls. Purchasing will ensure contracts subject to Davis Bacon Act requirements will clearly outline the responsibilities of the general contractor, as well as requiring flow down to subcontractors. For the Animal Care Complex project partially funded by the EDA award, Purchasing will request certified payrolls dating back to the start of the project from the contractor and subcontractors. Certified Payrolls will only be accepted via DOL form WH347. Texas Biomed has engaged an external project management firm to support extensive new construction underway or soon to commence on Texas Biomed’s campus. The consultant, as part of the scope of their engagement, will serve as the first reviewer of invoices and pay apps, and payment requests will not progress without their approval. The review will include verification of inclusion of necessary certified payrolls. Documentation will be saved in a shared Dropbox folder, where Texas Biomed Facilities personnel will review and sign off on the cover letter from the consultant, verifying Texas Biomed’s review of the necessary certified payrolls at that time. When the pay app is entered by Texas Biomed Accounts Payable in the automated system for invoice payment, the payment request will automatically route to a designated Texas Biomed Facilities staff member. This second staff member will provide a final review of the certified payrolls as a condition for approving the invoice for payment. Both Facilities staff members will have access to the certified payrolls and approval at each step will signify the necessary documentation has been received. If there is a lack of proper documentation, Facilities personnel will alert Accounts Payable of the reason for delay. Facilities personnel will follow up with the project management consultant and contractor to request additional backup when necessary. Responsible Parties: Amber Garcia, Facilities Operations Coordinator; Mike Merz, Principal Engineer; Patricia Thompson, Assistant Director, Materials Management Completion Date: December 31, 2024

Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Federal Agency Name: Department of Treasury Pass‐Through Entity: North Dakota Office of Management and Budget Assistance Listing Number: 21.027 Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In the testing of procurement, suspension, and debarment it was identified that the City did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Corrective Action Plan: The City has adopted a procurement policy satisfying the requirements of 2 CFR sections 200.318 through 200.326 as of January 8, 2024. Responsible Individuals: Dustin Scott, City Administrator Anticipated Completion Date: January 8, 2024

Corrective Action: CBNHC will implement the following corrective actions: • CBNHC will update its procurement policies and procedures to conform with 2 CFR Part 200. • CBNHC will implement training for all staff who perform program purchases to ensure compliance with its Finance Policies and Procedures. • The Accounting Supervisor, Accounting Technician, and Interim Finance Director/Chief Operations Officer will ensure that all new purchases comply with the CBNHC Finance Policies and Procedures. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Accounting Supervisor (Candyce Guerro) – Is responsible for conducting procurement policy training for all staff who perform program purchases. • Interim Finance Director/Chief Operations Officer (Volelle Zamora) – Is responsible for updating the procurement policies and procedures. • Interim Finance Director/Chief Operations Officer (Volelle Zamora), Accounting Supervisor (Candyce Guerro), and the Accounting Technician (Charlotte Sandoval) – Jointly responsible for ensuring incoming purchase requisitions are in compliance with the purchasing policies and procedures. Completion Date: CBNHC will update its procurement policies and procedures by December 31, 2024. Training over the current procurement protocol will be implemented immediately and will be conducted annually for all program managers. The Finance Department will immediately review all incoming purchase requisitions to assure requests comply with policy standards.

Finding 2023-005 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: Steve McFarland, City Administrator 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, 2024

Procurement Process Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Passed through the Oklahoma State Department of Education (Fund 723) Compliance Requirement: Procurement Material Weakness in Internal Control over Compliance; Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. 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. Effective May 14, 2022, the non-Federal entity must ensure that all applicable programs comply with section 70914 of the Build America, Buy America (BABA) Act, including through incorporation of a Buy America preference in the terms and conditions of each award with an infrastructure project. Condition: A vendor that was funded by the ELC program had not gone through the procurement process as required by applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The District has previously funded the vendor using state and local funds rather than federal funds for the past several years. The vendor’s service was identified that the use of the funds was an allowable activity and cost but the vendor had not gone through the required procurement process for federally funded programs. Effect: The District is out of compliance with federal requirements regarding procurement and could be contracting with vendors that are not the most practical for the District. Context/Sampling: Both of the two vendors that met this scope in this program was tested so no sampling was necessary. Repeat Finding From Prior Year: No Questioned costs: Funds spent with this vendor in this program were $486,260. Recommendation: Control procedures should be implemented to ensure that all vendors that are paid with federal funds following the required procurement regulations and ensure federal updates are regularly made to ensure continued compliance with procurement requirements.Views of Responsible Officials: The district understands the importance of complying with federal procurement requirements and will ensure all staff involved with federal funds are informed of the procurement rules with the addition of the federal compliance procedures to our Fiscal Management Policy. Responsible Individuals: Cameron Cox, Director of Purchasing Anticipated Completion Date: June 30, 2024

Auditor’s Recommendation: We recommend that the Foundation 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: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings. • As a First Year Single Auditee, the management team will ensure that specific policies are created to ensure a procurement process for goods and services expensed from federal funds is established and in alignment with UG (Uniform Guidance) standards for federal awards. • As a First Year Single Auditee, the management team will have an independent audit firm review this policy to ensure they are in alignment and conformance with UG (Uniform Guidance) standards.

The Chief Procurement Officer will follow all federal and state procurement standards. CPO will review and make necessary changes to documentation procedures for procurement to ensure that all federal and state requirements are met. Chief Procurement Officer has reviewed federal and state procurement compliance. He will update changes to documentation of procurement by December 31, 2024

The District will communicate with the team at DESE to determine what is needed to bring all files current.

The District understands fully that all state and federal spending must follow guidelines set forth in the grant or amount allocated.

Accounts payable will not release funds until all guidelines and documents are secured and attached to the Purchase Card of Purchase Order form. The district has appointed a different Federal Program Coordinator and this action has been practiced since January 2, 2024.

The District will conduct a training to inform supervisors what forms and guidelines are required prior to the release of any monies by the end of July 2024.

2023-003: 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 ten of 25 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Repeat Finding: Similar to prior year finding 2022-003. 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, 2024 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer