Corrective Action Plans

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.

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.