Corrective Action Plans

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.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Documented evidence of the implementation of the control process was not maintained. Due to the lack of controls, it could not be determined that the school corporation ensured compliance with the grant agreement. Proper safeguards were not in place to ensure that documentation was properly maintained, causing the CFO and Food Service Director to be unable to locate the documentation for each procurement method. Contact Person Responsible for Corrective Action: Allison Pund and Margaret Leavitt Contact Phone Number and Email Address: 812-683-3971 x5002; punda1@swdubois.k12.in.us; leavittm@swdubois.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: NA Description of Corrective Action Plan: The School Corporation will establish a proper system of internal control and develop policies and procedures to ensure all requirements are followed. Creation of these policies and procedures will be created by the CFO and Food Service Director. Internal controls will be put in place to ensure these policies and procedures are followed. In addition, the Food Service Director will maintain all bids, contracts, and other documentation to support the procurement methods used and will verify suspension and debarment prior to entering into covered transactions of $25,000 or more. Anticipated Completion Date: August 2025

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.

Action Taken in Response to Finding: Procurement practices were maintained and subsequently standardized and incorporated into Financial Policies and Procedures. A Procurement Policy aligned with 2 CFR §§200.317–200.327 was implemented and includes requirements for: • Documenting procurement methods • Ensuring full and open competition, where applicable • Performing cost or price analysis when required • Maintaining procurement records sufficient to support decisions These requirements have been integrated into financial operations to ensure consistency and compliance across all Federal awards. Control Enhancement: A standardized procurement framework has been implemented requiring: • Documentation of procurement method (micro, small purchase, competitive, or sole source) • Documentation of vendor selection and rationale • Cost or price analysis for applicable procurements • Justification and approval for noncompetitive procurements All procurement actions are supported by documentation demonstrating compliance with federal requirements. Monitoring & Review: • Procurement transactions are reviewed prior to execution of vendor agreements funded with Federal awards • Documentation is submitted to the Director of Finance & Operations for review • Review and approval are performed in accordance with established approval thresholds Testing & Validation: • Beginning in June 2026, periodic internal reviews will be conducted to assess procurement files for compliance with Federal requirements • Testing will confirm: o Proper procurement method selection o Adequate documentation of vendor selection o Completion of cost/price analysis where required Documentation & Evidence: • Procurement files maintained in Teams / SharePoint • Documentation includes procurement method, vendor selection, and pricing support • Approvals documented via workflow / contract approval process Control Owner(s): • Director of Finance & Operations • Finance Team • Program Leadership (as applicable) Responsible Party: Helen Young Hayes, Founder / Chief Executive Officer, in coordination with the Director of Finance & Operations Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monitoring and periodic validation will continue. Status: • Formalized Procurement Policy: Implemented in May 2023, • Monitoring documentation (memorandum and checklist): Implemented in 2024; Strengthened with additional structure and controls, with support from an outside professional services firm - CliftonLarsonAllen(CLA)’s grant management team, leveraging their experience in federal grant compliance Grant Management framework Integrated into Financial Policies and Procedures: Completed May 2026 • Periodic internal reviews will be conducted to assess procurement files for compliance with Federal requirements: June 2026.

August 20, 2026 To: Clausell & Associates, P.C. From: Mary Harrison, Executive Director of CSRA Economic Opportunity Authority, Inc. Below is the Authority’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2023, Single Audit Act audit. Comment #2023-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will require additional specialize training for fiscal staff and improve in the segregation of duties to ensure adequate internal controls are fully implemented. The Executive Director will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The Executive Director will take the lead in financial reporting to ensure that all reporting meet GAAP and GAS requirements and to provide informative reports for Board and Management. All enhancements will be implemented by September 30, 2026. Concerning the preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, etc.), the Authority will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than September 30, 2026 Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action. Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on grant accounting, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by September 30, 2026. See also the response to Comment #2023-001. Implementation Date: The plan correction date will be completed no later than September 30, 2026. Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action.

Condition: Controls were not sufficient to ensure that management has written policies and procedures surrounding procurement that align with Federal Procurement Standards outlined within the Uniform Guidance. Further, controls were not adequate to ensure that the history of procurement decisions was documented. Additionally, controls were not sufficient to ensure checks for suspension and debarment were performed and documented before entering into a covered transaction with third parties. Planned Corrective Action: The Organization will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2024

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