Corrective Action Plans

2023-002 U.S. Department of Transportation, National Infrastructure Investments: Better Utilizing Investments to Leverage Development (BUILD) Grant Assistance Listing Number 20.933; Procurement Material Weakness in Internal Control over Compliance Finding Summary: 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. The Port Authority’s formally documented policy pre-dates Uniform Guidance and does not include many of the necessary procurement provisions. Corrective Action Plan: An updated Procurement Policy is being drafted to meet the standards set forth in 2 CFR 200.317 to 220.237, then reviewed and approved by our Board at the next appointed board Meeting. Expected Completion Date: March 2024 Responsible Individuals: Kimbra Scott

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 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 work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so its clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2024.

FINDING 2022/2023-004: Wage Rate Compliance Response: The District has policy# 8502 already in place and was adopted in April of 2022. The next time a construction job comes up in the district and is over $5000.00 and being paid out of federal funds, the district will ask for payroll reports that show prevailing wages.

Initial Fiscal Year Finding Occurred: 2023 Federal Agency Name: U.S. Dept of Housing and Urban Development Program Name: Continuum of Care CFDA #: 14.267 Finding Summary: Significant Deficiency over Internal Controls over Compliance. Procurement, Suspension, and Debarment During testing, it was identified that the Organization was not following its procurement policy. Responsible Individual: Theresa Perkins, Chief Financial Officer Corrective Action Plan: The NAC leadership team is responsible for the following and will report on the following for FYE 2024: Provide a final Procurement Plan that has been reviewed and updated and approved by the Board. Anticipated Completion Date: June 30, 2024

Official Responsible for Ensuring CAP Lorie Werle, business manager, will be responsible to ensure that the appropriate measures are taken. Correcting Plan The District will provide Lorie Werle, business manager, necessary training. The Planned Completion Date of CAP Immediately

Finding – Internal control deficiencies over procurement requirements Name of contact person: Lane Millar, Finance Director Corrective action: The City will ensure that employees receive comprehensive training on procurement requirements as a prerequisite before undertaking those responsibilities. Proposed completion date: March 1, 2024

MW Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to add in the other methods of procurement to ensure compliance with the Uniform Guidance and follow proper document retention procedures. 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, 2024

Contact Person Theresa Brien-Knutson, Business Manager Planned Corrective Action The District will plan to get payroll registers monthly from the contractors moving forward. Planned Completion Date June 30, 2024

Contact Person Theresa Brien-Knutson, Business Manager Planned Corrective Action The District will plan to get payroll registers monthly from the contractors moving forward. Planned Completion Date June 30, 2024

Somerset County Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Audit Period: July 1, 2022 through June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING- MAJOR FEDERAL AWARD PROGRAM AUDIT U.S Department of Agriculture 2023-001 Paper/Chemical Product Contract Recommendation: The Board should follow its established procedure and policy providing for competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Board has entered into a competitively sourced contract with FPC Holding, Inc. as of December 2023 for the purchase of these products. Name of contact person responsible for corrective action: Linda R. Johnson, Director of Finance Planned completion date for corrective action plan: December 1, 2023

Finding 2023-002 Procurement Corrective Action: TPOCC has updated its Finance Manual, inclusive of a procurement policy in compliance with Uniform Guidance (2 CFR Part 200). We have also had all management staff who deal with programs funded by Federal Funds attend training on Uniform Guidance. We will continue to have staff attend these training courses to ensure that they are familiar with the requirements of Uniform Guidance. We have also begun implementing a procurement system (Pairsoft Paramount Workplace) and anticipate a go live of April 1st, 2024. This will help ensure our procurement policies are implemented and followed uniformly. Person Responsible: Finance Director, Lacy Meneses and CFO, Will Goodall Timing for Implementation: Currently in progress and procurement software will Go Live on April 1st, 2024. Document ID: b51a2bdf940fc8367245121fabb689a6083edd8e9deb8925c16c8fec9313f6b8 Page 1 Summary Schedule of Prior Year Findings and Questioned Costs Turning Point of Central California, Inc. did not retain procurement records to support its assertion that it is contracting with vendors that provide the best prices. Turning Point of Central California, Inc. has not updated its procurement policy to comply with the Uniform Guidance (2 CFR Part 200). This finding was first reported in the June 30, 2021 audit, issued in June 2022, and Turning Point of Central California, Inc. did not have adequate time to implement its corrective action plan during the year ended June 30, 2023. Questioned Costs: None

2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation supporting that vendors were reviewed for suspension and debarment. There was also no documentation for review of the procurement transactions tested. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: Changing the personnel involved has solved much of the problem, also the full awareness of what needs to be retained has also been explained to management. Management intends to add a Director level executive in the spring of 2024 to fully review and revise where necessary all standard operating procedures, including that of procurement. If/when funds from federal sources are used, those expenditures will be reviewed monthly. Specifically, this will mean: -Maintain EIDL‐sourced funds in a separate bank/account - Have single authorization for any movement/usage of funds in EIDL account - If/when funds from EIDL are used, have a written statement for purposes and documentation produced for use at the time of request Responsible Individuals: -Maintain separate account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024

Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Corrective Action: School did not have an HR Manager for school year 2022‐23 and the School recently hired an HR Manager. The Business Manager, with the help of the HR Manager, will ensure that School policies with sealed bids will be followed. The Business Manager will maintain all quotes  and  documentation  from  vendors.  The  School’s  current  policy  will  be  reviewed,  and  language will be added to address quotes and thresholds.

Finding Number: 2023‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Schools Student Transportation Assistance Listing Numbers: 15.042, 15.046 Contact Person: Aurelia Tapaha, Business Manager/Human Resource Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2024 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.

Finding # 2023-001 Condition: Ampla Health did not have adequate procurement policies in place that meet the minimum federal requirements for procurement standards. We examined the procurement records for nine vendors where Ampla Health expended federal funds. For all four sole source procurement records reviewed, Ampla Health did not retain documentation of the sole source determination or have an approved sole source vendor list. For two of three vendors selected in the small acquisition threshold, Ampla Health could not provide competing quotes or sufficient evidence to demonstrate procurement was performed. For one of three vendors selected in the small acquisition threshold, Ampla Health was only able to provide procurement support for a portion of the funds expended. Response: Management will review the procurement policy and make all necessary changes to ensure we are in compliance with all federal requirements Responsible Party: Kathy Walker, CFO Estimated Completion Date: May 1, 2024

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, Associate Director Corrective Action Plan: Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon completion of training, the team will provide the Finance Committee of the Board of Directors with suggested updates to our current policy. Anticipated Completion Date: March 31, 2024

Finding 2023-004 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation that the procurement of the CNG tank replacement project for five Orion buses exceeding the simplified acquisition threshold of $250,000 was approved by the Board. There is documentation that an invitation for bid (IFB) was released for the project, but only one bid was received, and the District awarded the contract to the sole bidder. Missing documentation includes support of the rationale to approve the contract absent evidence of full and open competition. The District was also not able to provide the request for proposal for review. Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following: • Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.” • Section 200.318(i) states that “The non-Federal entity 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.” • Section 200.320(c) states that “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold…; (2) The item is available only from a single source; (3) The public exigency or emergency for the retirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.” • Section 200.324(a) states that “The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals.” Cause: Staff turnover at the District and the need for the project to be completed by a certain date to avoid the buses losing certification led to the lack of adequate records being maintained. Effect: The District was unable to prove it was in compliance with the Uniform Guidance regarding open competition on procurements. the buses to be operational, so not every step was documented. The awarded contract was signed on the date of a Board meeting, but the Board minutes did not document that this contract was reviewed nor approved by the Board. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management agrees with the recommendation and acknowledges the importance of complying with uniform guidance regarding open and competitive procurements. Due to key staff turnover, the District could not locate documentation for the CNG tank replacement procurement to prove compliance with uniform guidance. In addition, the reason the agreement was not brought to the Board for approval could not be determined by current staff. To address the issues, the District will review its procurement and documentation procedures in addition to establishing checklists to ensure compliance and proper records retention.

Views of responsible officials and planned corrective actions - The Organization will develop a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Transit Cluster 20.507 Formula Grants for Rural Areas and Tribal Transit Program 20.509 Contact Person: Shelly Kreger, Transit Director Anticipated Completion Date: May 27, 2024 Planned Corrective Action: YCIPTA has released an RFP for Cardlock Fuel Services on March 25, 2024, with an anticipated contract award date of May 27, 2024. Services to begin on July 1, 2024. Two of YCIPTA staff are in Procurement training, attending the full NTI Procurement Series with one of them being dedicated to procurement. All future procurements will be going through this person to make sure that all policies and procedures are followed. For the two purchases that quotes were not obtained, staff will obtain quotes no later than April 30, 2024.

The City of Tracy, California respectfully submits the following corrective action plan for the reported findings for the fiscal year ended June 30, 2023. The findings are numbered consistently with numbers assigned in the June 30, 2023 Single Audit Report. Finding 2023-001 Procurement Policy 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. A non-federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $3,500 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(c); the competitive proposals method under the conditions specified in 2 CFR section 200.320(d); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(f). Finding 2023-001 Procurement Policy (Continued) Criteria (Continued): 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(d)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR part 200, “Contract Provisions for Non- Federal Entity Contracts Under Federal Awards.” Non-federal entities had a grace period of two full fiscal years after the effective date of the Uniform Guidance before they had to comply with the procurement requirements of 2 CFR section 200. For a non-federal entity with a fiscal year-end of June 30, its effective date for the procurement requirements was July 1, 2017. However, during this grace period, non-federal entities were required to clearly document whether they decided to comply with the previous version of the applicable procurement standards or the new standards contained in the Uniform Guidance. Condition: The City has not updated its purchasing policies and procedures to bring it into compliance with the requirements of Uniform Guidance. The City has also not formally documented whether it has decided to extend its applicable date of compliance with 2 CFR part 200 to be effective beginning July 1, 2018. Context: See condition above for context of the finding. Cause: The City has not evaluated its existing procurement policies for compliance with the requirements of the Uniform Guidance. Effect: The City is not in compliance with the procurement policy provisions of 2 CFR part 200 and the Uniform Guidance. Not updating the City’s procurement policy could lead to future findings and questioned costs related to federal awards. The current audit did not identify noncompliance with direct and material compliance requirements of the major federal award program. Identification as a Repeat Finding: Yes. 2022-001. Recommendation: The City should evaluate and update existing purchasing policies and procedures in order to bring the City into compliance with the procurement policy requirements of 2 CFR part 200 and the Uniform Guidance. The updated policy should include, among other things: Finding 2023-001 Procurement Policy (Continued) Recommendation (Continued): 1. Thresholds and appropriate approval procedures for allowable federal procurement methods. 2. Written standards for how conflicts of interest involving employees engaged to select, award, and administer contracts will be governed. 3. How to ensure that contracts and awards are made only to responsible and eligible contractors and how oversight of contractor performance will be monitored. 4. How records will be maintained in order to document the history of federal procurements. Corrective Action Plan: The City is still in the process of working with an outside firm on a review of procurement and purchasing policies. The consultation includes compliance review of this standard. Anticipated Completion date: July 1, 2023 Name of Contact Person: Sara Cowell, Finance Director

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement, Suspension and Debarment Summary of Finding: Insufficient documentation provided for proof of Procurement and Suspension and Debarment verifications Contact Person Responsible for Corrective Action: Ghirmay Alazar (Procurement) Phyllis Ritenour (Suspension & Debarment) Contact Phone Number and Email Address: 317-845-9400 galazar@msdwt.k12.in.us pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Procurement - At our educational institution, we prioritize the unique leaning needs of our students by actively seeking vendors who can effectively meet our expectations. To ensure transparency and fairness in the vendor selection process, we examine total costs estimates from each vendor and analyze their reputations, experience, customer feedback, and ability to provide innovative solutions. We use this information to make informed decisions and the rationale behind our vendor selection process. When searching for vendors we will keep documentation that displays the cost from each vendor and the rational for selecting a specific vendor. Suspension and Debarment – Beginning July 2024 the Assistant Accounting Manager will run reports annually in July from sam.gov and from FMS and compare the 2 files to make sure that we don’t have vendors in our system that are on the debarment list. The files will then be forwarded to the Accounting Manager via email for review and approval. The approval email and the 2 reports will be saved in our shared drive as proof of file review. All new vendors will be checked in sam.gov before allowing purchases to be placed. The review sheets will be emailed to the Accounting Manager for review and approval, these will also be saved in our shared drive. Anticipated Completion Date: Procurement – December 2024 Suspension & Debarment – July 2024

Auditor’s Recommendations: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors who are not suspended or debarred. The District may have the vendor provide an annual certification that is s not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive, but also effective, in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for funding: The procurement Officer of SJSWCD has updated the procurement process on 12/7/23 that all contractors who will be receiving Federal monies must provide an annual certification that they are not suspended, debarred, inactive, or otherwise excluded from participating in transaction funded through Federal grants. The policy change will be approved at the next board meeting. • Timeline for completion of corrective action plan: December 7, 2023 • Employee position(s) responsible for meeting the timeline: Oralia Bridge, District Manager

Finding: 2023-001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 – Coronavirus State and Local Fiscal Recover Funds CFDA #: 21.027 Compliance Area: Procurement, Suspension and Debarment Initial Fiscal Year Finding Occurred: 2023 Finding Summary: During the course of the testing over the federal program, it was noted that while the City does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, elements that are required to be included in contracts with vendors who are paid using federal monies were missing from the contracts. This was due to the fact that the City had not had single audits performed until recently as a result of the increase in funding due to the COVID-19 pandemic. Because of this, they had not updated their purchasing policy to be compliance with Uniform Guidance. Responsible Individuals: Chief Financial Officer Procurement Manager Corrective Action Plan: City will update existing Purchasing Policy to include the necessary elements as noted in the Uniform Guidance. City will update future contracts associated to grant dollars to include the necessary elements as noted in the Uniform Guidance. Anticipated Completion Date: City will have the Purchasing Policy updated by June 1, 2024 to allow time for Legal Review public noticing timelines. City will have the Contract Language updated for the next applicable contract associated to grant dollars.

Finding2023-002: Criteria or specific requirement: Criteria or specific requirement (including

statutory, regulatory, or other citation): 29 CFR 5.5 (Wage Rate Requirements) requires all contractors and subcontractors performing construction contracts in excess of $2,000, financed by federal assistance funds, to pay laborers and mechanics employed by the contractor or subcontractor not less than the prevailing wage rates established by the Department of Labor for the locality of the project. Non-federal entities shall include in the applicable construction contracts a provision that the contractor or subcontractor comply with those requirements.