CORRECTIVE ACTION PLAN Greg Lunsford, Town Manager, respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 22801 Audit period: June 30, 2022 The findings from the June 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-010: Water and Waste Disposal Systems for Rural Communities - AL# 10.760, Late Filing of Data Collection Form Condition: The Town did not file the data collection forms for the years ended June 30, 2022 and June 30, 2020 timely. Criteria: Under the requirements in the Uniform Guidance and the Office of Management and Budget (0MB), all entities are required to file the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the entity's annual audit or twelve months after the entity's fiscal year end (June 30 th for the Town of Elkton). Cause: Management did not complete and certify auditee portion of the form before the deadline. The form was not completed for either years ended June 30, 2022 and June 30, 2020. Effect: The Town's form was not submitted to the Federal Audit Clearinghouse. Recommendation: Management should take steps to ensure that the form is filed timely. Corrective Action: The Treasurer is aware that an annual audit needs to be completed for all major federal awards and will work with the auditing firm to provide the necessary information for compilation of the report by the stated deadline. 2022-011: Federal Procurement Policies Condition: There are no written procurement policies specific to the federal awards cost principle requirements under Uniform Grant Guidance. Existing procurement policies are minimal and do not meet federal requirements. Criteria: Federal award recipients must have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E. Cause: Certain required policies under 2 CFR 200, Subparts D and E are not present. Effect: Lack of required policies may create noncompliance with regulations as stated requirements may not be followed. Recommendation: Develop procurement policies and financial policies that meet federal standards. Corrective Action: The Treasurer has drafted a Procurement Policy for Council to review and approve for implementation. Should the Federal Audit Clearinghouse have questions regarding the Corrective Action Plan or require additional information, please contact Donna D. Curry, Treasurer, at (540) 298- 9465. Respectfully, Greg Lunsford Town Manager Town of Elkton, Virginia