Corrective Action Plans

City staff incorporated the following changes in the CDBG procedures to ensure future PR29 CDBG Cash on Hand quarterly reports are complete, accurate, and submitted to HUD within IDIS before the due date and that City receives confirmation on their submittal: (1)Consultant, or other PR 29 preparer, will calendar the PR 29 submittal due dates to ensure timely submittal. (2) The consultant or other PR 29 preparer will provide the Housing and Community Services (HCS) Manager and HCS Coordinator with a copy of the submitted report, indicating the submittal date, and a screenshot from the Integrated Disbursement and Information System {IDIS) database verifying the submittal date. (3)HCS staff will calendar a PR 29 submittal reminder two weeks before the submittal due date. (4)HCS staff will follow up with the designated PR 29 preparer until the submittal is verified. (5)Communicated and formed agreement between City staff and consultant on implementing the aforementioned procedural changes.

Recommendation: We recommend that the Organization review its current documented procurement policy, and its current processes and controls over procurement and suspension and debarment to ensure all required elements are included and the appropriate level of documentation is retained and available. Views of Responsible Officials and Planned Corrective Action: RTDCA will revise its documented procurement policy to adhere to the federal procurement policy mandates and ensure all required elements and documentation are retained. Person Responsible: Ms. Katharine Dixon, President and CEO Planned Completion Date: By September 30, 2025

Finding Number: 2024-001 Condition: Controls were not sufficient to establish written policies and procedures surrounding procured contracts and to ensure that the history of procurement decisions were documented, as required by 2 CFR 200. Context - Institute's Management did not maintain adequate records for three of the four noncompetitive contracts, including details on procurement history. Additionally, for contracts under both the Research and Development Cluster and the ELC contract, management failed to provide evidence of suspension and debarment checks for contractors before entering into transactions. However, there was no evidence of contractors being suspended or debarred, and no questioned costs were identified. Planned Corrective Action: Management agrees with the recommendation and will review the relevant guidance to ensure compliance. Necessary revisions will be made to the existing procurement policies and procedures in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200. Contact person responsible for corrective action: Lavenia Bell, Accounting; Teresa Martinez, Senior Post Award Coordinator; Mariela Romo, Administrator Anticipated Completion Date: 8/31/2025

Recommendation: We recommend the County follow procurement policies in place at the County or outlined in the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: Going forward, the county is committed to enhancing the efficiency and transparency of its procurement process for awarding contracts. We will ensure that all departments strictly adhere to the established procurement policy, fostering an environment of full and open competition. Additionally, we will implement annual training sessions for all departments to reinforce their understanding of the procurement policy and ensure ongoing compliance. Name of contact person responsible for corrective action: Jeffrey Rank, Director, Office of Budget & Finance Planned completion date for corrective action plan: February 28, 2025

Finding Number 2024-001 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: Management completed the documentation for vendor selection, justification and suspension and debarment search for the vendors selected in FY 24 audit prior to the commencement of the audit. These documents were provided to the auditors upon request. However, the auditors determined that since this was a finding in FY 23 and the approval from the funder was received during that audit, the finding would automatically have to be repeated because of the timing of the last audit. ULMS created a procurement form that streamlines the selection, justification suspension and debarment search and documentation of the process in March 2024. Additionally, management transitioned the form online in August 2024 for document retention purposes so that 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

U.S. Department of the Treasury, Passed through Lancaster County, Nebraska COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027 Procurement, Suspension, and Debarment: Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: The Organization does not have a formalized procurement policy that conforms to applicable standards under Uniform Guidance. Additionally, the Organization did not follow procurement policies when obtaining bids for contracts. Responsible Individuals: Natalya Young, Executive Director Corrective Action Plan: Procedures will be developed to ensure proper procurement transactions in accordance with the Uniform Guidance. Additionally, the Organization will follow procurement policies when obtaining bids for contracts. Anticipated Completion Date: June 2025

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Name of contact person: County Commissioners Corrective Action: Roosevelt County will follow the procedure of verifying contractors through SAM or GSA Websites when using SLFRF funds. Proposed Completion Date: Immediately.

FINDING 2024-002 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 FINDING 2024-002 (Continued) Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness 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 Food2School Child Nutrition Cooperative which procures vendors for food purchases and other supplies on behalf of its members. During the audit period, the School Corporation purchased supplies and equipment from vendors not procured by the Cooperative. One vendor with aggregate annual purchases of $118,390 and $68,859 for fiscal year 2023 and fiscal year 2024, respectively, exceeded the small purchase threshold ($50,000 - $150,000) and was not subject to the School Corporation’s procurement policy to solicit multiple quotes and to document the method and rationale for procurement. Suspension and Debarment For three 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: Shane Hacker, Assistant Superintendent of Operations; Corey Ebert, Director of Finance; Jordan Ryan, Director of Nutrition Services Anticipated Completion Date: February 1, 2025.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559, and 10.582 Recommendation: We recommend that the Board enhance controls and procedures to ensure that it follows its procurement policies for all goods and services charged to the program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Purchasing procedures and thresholds were discussed at a leadership meeting of the Department of Food and Nutrition Services. Specifically, the need for at least two quotes for purchases between $15,000 and $50,000 was reiterated. On an ongoing basis, expenditures by vendor will be reviewed to ensure compliance with the procurement policy. Name of the contact person responsible for corrective action: Jaime Hetzler, Director of Food and Nutrition Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

Federal Agency Name: Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Finding Summary: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Corrective Action Plan: Procurement, suspension and debarment procedures were largely decentralized across the agency. In response, the organization has an internal, cross-functional compliance team that has reviewed and is developing process changes to ensure appropriate systems are developed and documentation is maintained for purchasing related to federal programs. Responsible Individuals: Chief Legal Officer, Controller Anticipated Completion Date: June 30, 2025

Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: In our testing of procurement, suspension and debarment it was identified that the District did not go out for quotes on one contract over the mircro purchase threshold. Responsible Individuals: Beth Slette, Superintendent Corrective Action Plan: The District will ensure all contracts comply with their procurement policy and the procurement standards as identified in 2 CFR sections 200.317 through 200.327. Anticipated Completion Date: June 30, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No. Direct allocation and AM-23-0287 Name of contact person: Kelly Strecker Corrective Action: The City commits to ensuring that a procurement policy be put in place that will allow it to comply with procurement standards outlined in the Uniform Guidance. Proposed Completion Date: Immediately

MATERIAL WEAKNESS 2024-002 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Procurement Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One City Schools adopted a procurement policy in November 2023 that, if followed, resolves this finding. A new primary food vendor was selected in summer of 2024, and the selection did adhere to the new procurement policy. This policy and all procedures were edited to be comprehensive of all uniform grant requirements through the development and adoption of the Federal Funds Procedural Manual. Name(s) of the contact person(s) responsible for corrective action: Janel Vertz, Finance Director Planned completion date for corrective action plan: January 2025

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

December 18, 2024 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Subject: Response to Uniform Guidance Audit Finding for FY23-24 Finding 2024-001 Procurement Significant Deficiency Federal Program: Charter Schools Program Assistance Listing Numbers: 84.282A Springville Community Academy (SCA) plans to develop a written procurement policy that incorporates the Federal regulations and procurement standards identified in §200.317 through 200.327. I, Corbin Dietrich, will work with the Board of Directors of SCA and our consultants with Indiana Charters to develop the appropriate procurement policies and procedures. We plan to draft and approve the required policies at the board meeting in January 2025. Sincerely, Corbin Dietrich, Treasurer

FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A210084, H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Procurement and Suspension and Debarment compliance requirements. Context: During the audit period, the School District purchased Special Education contracted services from one specialist with aggregate payments for each fiscal year which were within the small purchases threshold ($10,000 - $150,000) under Federal and State procurement regulations. The School District did not solicit multiple quotes for services, document the method and rationale for procurement, and did not perform a check to confirm the service provider was not suspended or debarred before entering into the contract and disbursing federal funds. FINDING 2024-005 (Continued) Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement a procurement checklist that is reviewed management to ensure compliance with the School's purchasing policy for federal awards. Sam.gov will be checked for each vendor being paid from Federal Funds. Responsible Party and Timeline for Completion: Moriah Crane - Treasurer and Andrew Grismore - Grant Coordinator starting immediately.

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2024 FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: Procurement 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 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. 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 $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation's policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation's contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the School Corporation's procurement policy is being followed for all procurement thresholds. Management will perform a periodic check of federal fund disbursements to see if any vendors exceed procurement or suspension and debarment thresholds on an annual basis to ensure compliance with federal and state procurement guidelines. The School Corporation will ensure that all contracts exceeding $25,000 include a suspension and debarment clause and will verify that the vendor is not suspended or debarred prior to entering into the contract. Responsible Party and Timeline for Completion: The Food Service Department has already implemented these changes as the issue was not present in fiscal year 2024.

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely with USDA representatives as we have moved through the program. A budget for all costs was approved as part of the grant award. All invoices, including all engineering fees, are approved directly by our assigned Area Specialist. The project costs are currently all within budget. The Village of Lexington will ensure that engineering services follow correct procurement procedures in any future grant program it is awarded.

Procurement Recommendation: We recommend that management develop, adopt, and implement written procurement and conflict-of-interest policies that comply with Uniform Guidance requirements. These policies should address procurement standards, including methods of procurement and oversight, and establish standards of conduct governing conflicts of interest for employees, officers, and agents involved in the administration of federal awards. Management should also ensure that these policies are communicated to relevant personnel and applied consistently. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2024 new maintenance staff was employed 3 bids are required for capital projects. If one contractor has personal relationship with employee conflict of interest form is filed. Name(s) of the contact person(s) responsible for corrective action: Kristin Cowan Planned completion date for corrective action plan: July 2024

We do not agree with the finding. The FASS-PHA cannot be submitted until the Single Audit is completed and issued. We acknowledge that the unaudited FASS-PHA was submitted late, and evidence was provided and the report was approved by HUD. We have the audited submission in draft pending the issuance of the Single Audit. The Municipality has developed an internal plan with the auditors and consultants to perform all pending Single Audit to the Federal Audit Clearinghouse as soon as possible. The Single Audit for the fiscal years ended June 30, 2024 and June 30, 2025 are already contracted and are expected to begin in August 2026. Personnel in charge: Daiana González Hernández, Finance Office Director Projected Completion Date: August 30, 2027

2023-012– EDUCATION STABILIZATION FUND - REPORTING – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain documentation for the data that was submitted to the North Dakota Department of Public Instruction (NDDPI) for the state’s completion of the Annual Report for the Education Stabilization Fund program. We were able to obtain the information that was submitted from NDDPI; however, due to issues identified with the accuracy of underlying accounting records we were unable to determine if the information included in the report is accurate. Management’s Response: We agree. The District will work to ensure that all federal programs reporting requirements are met going forward. The district has implemented new documentation retention requirements. Anticipated Completion Date: FY 2025

2023-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

The Board of Supervisors will ensure staff are properly trained in procurement policy and future procurement activities comply with both Uniform Guidance and Mississippi Law. Anticipated Completion Date: 9/30/2025. Contact Person: Otis Griffin, County Administrator

Corrective Action: Request proof of contractor not being on the suspension or debarment listing from Engineering Firm. This finding was due to funds being transferred to a project that became a federal project once utilized. Stillwater County is careful when selecting contractors and as part of the bidding process assures that the contractors are in good standing. Additional vetting was needed when the funds were transferred to the project and the County was unaware of this requirement.

The City of North Bend acknowledges that a contract utilizing SLFR funds, and awarded to a software vendor, did not include within the contract, a required self-attestation concerning Suspensions and Debarment. The self-attestation was used in lieu of a documented review of the SAM.gov portal for suspensions and debarment. This was an oversight of the contract review process. Other contracts issued during the same period included self-attestation language from 2 CFR 200.317 through 2 CFR 200.327. In 2024 and 2025, the Public Works Deputy Director, Contract Specialist, and Capital Staff Accountant ensure adherence to all applicable local, State, and federal procurement laws and regulations as provided in the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibiting recipients from entering into contracts with suspended or debarred parties. The City of North Bend understands the significance of the finding and immediately took steps to review all subsequent contracts for compliance.