Corrective Action Plans

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.

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