Corrective Action Plans

Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Context: The School Corporation did not obtain price or rate quotes for one out of four vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation of vendor contract, bids or the School Corporation's process and rationale for the chosen vendor was not available for audit. Further, the School Corporation could not provide evidence that a suspension and debarment check had been performed on the vendor prior to entering into contract. Corrective Action Plan: The Special Education Director will obtain pricing quotes from the appropriate amount of qualified sources, when cumulative costs are projected to exceed the micro purchase threshold. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Person responsible for implementation and projected implementation date: The Special Education Director, the Business Manager, and the Superintendent will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

2024-006 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2024-2025

March 26, 2025 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-001 AREA: Procurement and Suspension & Debarment Compliance It was noted that (1) the Organization's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327; and (2) in accordance with 2 CFR Part 180, contracts cannot be entered with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. It is recommended for the Organization to comply with the Organization’s internal procurement policies and the Uniform Guidance with respect to obtaining vendor quotes and retain support for a check of suspension and debarment. CLIENT PLANNED ACTION: 1. WellPower will review and align its procurement policy with Uniform Guidance compliance requirements for procurement, suspension & debarment. 2. WellPower will provide the necessary training on Uniform Guidance procurement compliance requirements to its procurement department and other authorized purchasers within the organization 3. WellPower will update its suspension & debarment check procedures and record keeping thereof, to ensure that SAM.gov checks of vendors are obtained prior to contract / purchase order issuance / purchase, and at a minimum annually. All records will be maintained with Procurement. CLIENT RESPONSIBLE PARTIES: Angela Oakley, VP & Chief Financial Officer Wes Williams, VP & Chief Information Officer COMPLETION DATE: May 31, 2025

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

x. Management Response and Corrective Action Plan: The first of the two identified vendors – Maxim/Amergis - is an employment agency with a specialty in staffing providers who work in the healthcare and social services field. NBCC was seeking to hire an RN. Significant documentable effort was invested in hiring an RN with the necessary experience to fill our vacant RN Healthcare Navigator position. After months of being unable to find an appropriate candidate, NBCC sought consultation from the Santa Barbara County Department of Public Health who advised us of the name of the employment agency (Maxim/Amergis) that is used by the Department of Public Health and Department of Behavioral Wellness to staff their RN positions. We reached out to Maxim/Amergis, provided them with the job listing, and reviewed resumes and interviewed candidates until we found an appropriate match. This was a prolonged and involved process where we spent a significant amount of time working to hire the best suited RN for working in the field with the homeless and formerly homeless individuals we serve. We did not perceive this to be a traditional procurement effort and therefore did not create a written analysis of our efforts to identify and hire an RN, nor did we conduct a SAM search on the company given that the company routinely staffs our departments of behavioral and public health. The second identified vendor is Paychex. We believe our efforts to secure a new payroll solution company were very much aligned with Uniform Guidance rules. Our external accounting firm and multiple staff spent more than one year interviewing multiple potential payroll solution providers, including but not limited to, Paychex, ADP, ClickUp, Inova, Credible, and Replicon, among others. We only reviewed two written cost proposals because only two of the researched and consulted companies were able to provide a solution that could potentially meet our government timesheet needs. We conducted multiple meetings with our external accounting firm and internal staff discussing and analyzing the solution options, but a summary of these discussions was not created. In addition, Paychex is a provider to a number of nonprofits we consulted, including a local grantee who was using their service, and who we were advised had developed a system similar to what we needed for our time and activity reporting requirements. We therefore presumed Paychex was not a debarred contractor given that other nonprofits we spoke to who have the same funding were utilizing their services. Moving forward, we recognize we must write a written analysis of our processes and that we should not assume a vendor has not been debarred given their existing customers and will be sure to confirm a company’s standing on SAM. As a further example of our commitment to always remaining current with procurement standards, at the direction of the Executive Director, our Operations Director had previously enrolled in a two-day Procurement Boot Camp training which occurred this week. Our Operations Director will revisit our procurement process as a result of this finding and after attending the procurement training and will make revisions to our procurement process as necessary to ensure future compliance with Uniform Guidance. Any updates will be made to the NBCC Internal Controls Manual and any new processes will be adhered to subsequent to those revisions. xi. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Brenda Lang, Operations Director, blang@sbnbcc.org Michael Dzierski, Finance Director, mdzierski@sbnbcc.org xii. Anticipated Completion Date: The anticipated completion date is May 31, 2025.

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to procurements thresholds, ACS will prepare a policy to follow the necessary federal guidelines. For small purchases, three quotes or bids will be obtained to ensure compliance with the procurement guidelines. For all vendors expected to exceed over $25,000 in expenditures will be kept in a binder by the Special Ed Director to ensure that they are not suspended or debarred from federal awards. The CFO will then review and approve the documentation supporting this via signature. Anticipated Completion Date: June 30, 2025

Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2025.

2024-002 - Reporting – Internal Control and Compliance over Reporting (Material Weakness) Condition: The City did not submit the required Cash on Hand Quarterly Report in a timely manner. The quarterly Cash on Hand Quarterly Report for the all of the four (4) reporting periods were submitted past deadline. Federal Financial Report 7/1/2023 - 9/30/2023: Report Submission Deadline 10/20/2023, Report Submission Date 2/26/2024. Federal Financial Report 10/01/2023-12/31/2023: Report Submission Deadline 1/20/2024, Report Submission Date 2/26/2024. Federal Financial Report 01/01/2024 - 03/31/2024: Report Submission Deadline 4/30/2024, Report Submission Date 10/16/2024. Federal Financial Report 04/01/2024 - 06/30/2024: Report Submission Deadline 7/30/2024, Report Submission Date 10/16/2024. Management concurs. Corrective Actions: Staff will ensure that report submissions are reviewed, approved, and submitted timely. Name of Responsible Person: Ron Garcia, Director of Community Development Ryan Mulligan, Housing Manager

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2024 FINDING 2024-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: We implemented policies and procedures in accordance with Uniform Guidance 2 CFR 200.214. Statement of Concurrence and Responsible Persons: We concur with the auditors' finding. Aracelis Suárez Finance Director Implementation Date: Fiscal year 2024-2025

2024-001Coronavirus State and Local Recovery Relief Funds – Assistance Listing No. 21.027 Recommendation: We recommend that management develop and implement written procurement policies and implement controls and procedures to ensure it maintains documentation of suspension and debarments checks and that the documentation is available for the audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 24, 2025.

Management Response: The Mifflinburg Area School District agrees with the finding. The SFA has updated Policy #626 Procurement - Federal Programs. The SFA has removed the RFP reference from the informal procurement method. The SFA reviewed the bidding requirements and will adhere to the policy. This policy was approved by the School Board in May 2024. The SFA has updated future produce solicitations to include the following: Pricing will be a cost-plus fixed fee structure. All prices bid for all products will be net, Free on Board (F.O.B.). SFA will consider individual product price changes both as part of a renewal to the awarded contract and during the contract year. Product price changes may not exceed the U.S. Department of Labor-Bureau of Labor statistics Northeast region not seasonally adjusted consumer price index percentage change annual average for the previous 12 months. Vendors must submit both the supplier charge and the fixed fee, which much be listed separately. Additionally, the SFA implemented a formal requisition process in the Food Service department, in which pricing would be entered into the requisition and verified against the bid or other respective documents, then submitted for approval. The SFA employees responsible were trained in this procedure. Individual Responsible: Superintendent, Business Manager, Food Service Director Anticipated Completion Date: May 31, 2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION; GRANT No. AM-22-0072 Name of Contact Person: Stacey Amundson Corrective Action: When the Glasgow City Council adopts a revised purchasing policy, it will include the process to run a background check on the lowest responsible bidder of a project and check the SAM system for all required entities before awarding the contract. Proposed Completion Date: June 2025

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the Responsible Official: We concur with the finding. Additional Explanation: Although the vendors selected provided specific services outlined in the federal grant, proper documentation of how those vendors were selected was not maintained. Moreover, the department believed by following the spending allotted in the grant, they were meeting necessary purchasing guidelines. Internal controls did not identify this misstep and allowed the services to be purchased. To avoid this in the future, guidelines will be prepared for all departments submitting purchase requests, and an additional control will be put in place to verify that procedures are followed. Description of Corrective Action Plan: 1) Create and write an administrative guideline that outlines expected purchasing procedures. 2) Distribute and make available the administrative guideline to employees. 3) Create an additional internal control in the business office to verify that those procedures were met with each requisition or request for purchase. 4) Provide necessary corrections to any request that does not follow guidelines. Mr. Armstrong will oversee, direct, and coordinate this process. He will work with the Corporation administrative team to develop and write the guidelines. The Business department will distribute the guidelines to all interested parties and have guidelines available upon request. Mr. Armstrong will outline expectations and determine when they have been met satisfactorily. Anticipated Completion Date: The remedy for this finding will be in place prior to June 30, 2025.

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to the SAM.gov website and CFR 200 guidelines. However, the department that applied for and accepted the grant failed to include CFR 200 Appendix II in the Professional Services Agreement and did not document the review of contractor status on SAM.gov. To address this, the City will provide targeted training for departments and staff involved in grants, focusing on compliance with grant policies, special provisions, and proper documentation of actions. Responsible Individual(s): Anna Guiles, Assistant Community Development Director Anticipated Completion Date: To be completed by 3/31/2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: City Manager Corrective Action: Employee training has been completed with all department heads to ensure future compliance with federal debarment requirements. We will do annual staff training on this and will work with our engineers to make sure they too are complying with the requirements. Proposed Completion Date: Ongoing

Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Shirley Klowetter, Secretary sklowetter@swraider.com Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Cluster and Procurement and Suspension and Debarment compliance requirements. Context: Procurement The School Corporation participates in the Region 8 Education Service Center Cooperative which procures vendors for many food purchases and other supplies on behalf of its members. During the audit period, the School Corporation contracted with vendors outside of the Cooperative. One vendor with aggregate annual purchases of$200,000 for fiscal year 2024 exceeded the simplified acquisition purchase threshold (greater than $150,000) but was subjected to small purchase acquisition instead of the policy to perform a formal procurement consisting of a request for proposal (RFP) that is publicly advertised. Suspension and Debarment For two vendors tested which were not procured by the Cooperative and had aggregate annual disbursements exceeding the federal suspension and debarment threshold of $25,000, the School Corporation did not perform suspension and debarment checks to confirm the vendors were not suspended or debarred before entering into the contract or disbursing federal funds. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement a procurement checklist that is reviewed after the purchasing process has been completed to ensure compliance with purchasing requirements for federal awards. Sam.gov will be checked for each vendor with aggregate purchases above $25,000. Responsible Party and Timeline for Completion: Superintendent or designee will immediately implement the above plan.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: Fallon County Commission/Clerk and Recorder Corrective Action: Procedures will be developed that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will follow all correct procurement plans set forth in the future. We will also verify with each vendor and have a form filled out stating that they are not suspended or debarred. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The School will ensure proper procurement methods are followed and that vendors are properly checked for suspension and debarment by December 2025. The additional controls will be implemented by August 2025.

The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Directors

OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Corrective Action Plan: Oregon Food Bank finalized and implemented a procurement policy and a specific procurement policy for purchases made with federal funds, aligned with federal procurement standards and effective October 2024. Internal controls will be established to ensure adherence to the policy, and procedures will require retaining documentation of the procurement process to demonstrate compliance. These improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date is June 30, 2026.

Contact Person Neil Breidenbach Planned Corrective Action The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Planned Completion Date December 31, 2025.

Finding 2024-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beverly Hindes Contact Phone Number: 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will ensure compliance with the Procurement and Suspension and Debarment requirement. Anticipated Completion Date: March 3, 2025

Federal Agency Name: Department of Labor Assistance Listing Number: 17.270 Program Name: Reentry Employment Opportunities Finding Summary: The Organization’s procurement policy did not contain all of the required procurement standards and contract provisions as required by Uniform Guidance. The organization entered into a covered transaction with a vendor before performing a review to ensure the vendor was not suspended or debarred. Corrective Action Plan: SHIP has had a long‐standing partnership with Sky Ranch Behavioral Services (SRBS), the lone applicant for the BOOST GO’s Violence Prevention Services RFP. Since SHIP serves as fiscal agent and employer of record for SRBS, SHIP would know if SRBS was on the disbarred list. Therefore, the Executive Director did not check to see if SRBS was suspended or disbarred. Despite having this knowledge, this action still should have been taken to tick the boxes on SHIP’s procurement policy, and to stay consistent with this practice being done for other vendors. The Executive Director takes full responsibility for this oversight. SHIP will review its procurement policy to ensure it matches federal guidance and will make necessary revisions (if any), and will take a draft to the SHIP Board of Directors for approval. Once approved, training will be provided to all Program Directors and relevant staff to ensure everyone understands the steps and procedures for the procurement policy. SHIP will also review all MOUs and subcontracts to ensure they match the federal requirements Responsible Individual: Matt Ohman, Executive Director Anticipated Completion Date: Revised Procurement Policy will be presented to the SHIP Board for approval and staff will be trained by June 2024, ready for new fiscal year contracts.