Corrective Action Plans

February 19, 2026 Christina Schaub, CPA Roslund, Prestage & Company P. C., CPA's 525 West Warwick Drive, Suite A Alma, Ml 48801 RE: Corrective Action Plan — City of Sault Ste. Marie — Single Audit Fiscal Year: 2025 M unicipality Code: 172010 Finding Number: 2025-001 Ms. Schaub: The City of Sault Ste. Marie was notified of a significant deficiency in its 2025 Federal Awards single audit report. Finding Type: Significant deficiency in internal control over compliance Program: ALN 97.044 — Assistance to Firefighter Grant . Grant Number EMW-2022-FG-01118 • Grant Number EMW-2023-FG-03417 • Grant Number EMW-2023-FG-02529 Criteria: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation. Managements Response/Corrective Action Plan: The City of Sault Ste. Marie has instituted the following measures to remedy this deficiency to be implemented immediately. 1. Management learned of this deficiency in response to a request for documentation of a check for debarment in connection with the single audit field work in October 2024 and again with the current single audit. Upon further inquiry, City staff didn't have documentation of this kind. This task slipped through the cracks because a process was not in place to ensure it was completed. 2. In reference to the City's Uniform Guidance Policies, most recently approved by the City Commission on February 17, 2025, page 44, the City will include a suspension/debarment clause in all written contracts in which the vendor will certify that it is not suspended or debarred. Alternatively, the city may request vendor/contractor sign a certification regarding suspension or debarment. Executed certificates and procurement files will be retained by the City Clerk's office. This language was in the policy but was not implemented. 3. A sample certificate is provided on page 53 of the unform guidance policy. This sample certificate, if completed, would have provided evidence but was not implemented. For future contracts, this certificate will be completed prior to the bid award and documentation that it has been completed will be required for future City contracts that are part of a federal grant award. 4. If for any reason this signed certificate is not available prior to the award bid recommendation, City staff will check the vendor's status on Sam.gov and will document the results in the narrative of the memo. This will be required for all contracts related to federal grants. City staff will be provided instructions about how to check the status as by the State of Michigan in the following link... https://www.michigan.gov/msp/-/media/Proiect/Websites/msp/EM HSD/grants2/instructions for checking for excluded debarred contractors revised 72020.pdf?rev=0a928fb6b4b54253b2a627f1eb70dcd8&hash=31DC61AC1AB1 E38D5A84952C43D27F82 5. Going forward, City staff will add a note to the narrative of the agenda memo in BoardDocs to state whether the City has a certificate or found that the vendor was not suspended or debarred a nd provide documentation to be attached to the memo for all bid award Recommendations. For example, we might indicate that the vendor/contractor was checked on Sam.gov and the contractor was not suspended or debarred and then follow up with a signed certificate when the contract is signed. Alternatively, a copy of the certificate, if separate from the contract, can be attached to the requisition in the P0 module. 6. This updated process will be shared with all project managers and grant administrators, along with staff in Finance and Clerks offices, so that we can ensure it is completed with each contract a nd project managers are supported during the busy construction season. 7. When bid award agenda memos route through Finance, they'll be reviewed to ensure this task has been completed and documentation is provided. This corrective action is being implemented as of this date and is expected to fully resolve the deficiency. Thank you for this opportunity for improvement. Sincerely, Kali Perron Finance Director/Treasurer

The University’s procurement policy will be updated to comply with federal requirements. The University will ensure the updated policy will be implemented and followed when acquiring funds to be spent with federal funds. The University will ensure that training and procedures are changed to be in compliance with the federal procurement, suspension and debarment requirements.

Finding 2025-001 Material Weakness in Internal Control over Compliance and Other Matters, and Material Noncompliance Corrective Action Plan: The observed finding was the result of inadequate staff training on the proper School Nutrition Procurement (SNP) guidelines. Newly responsible staff have attended multiple training sessions and are now fully aware of proper SNP procurement procedures. Stricter internal controls are being implemented to prevent recurrence and regular planning and forecast meetings will be held with the school nutrition team. Moving forward, The Sr Director of Purchasing and Materials Management will ensure purchases will be forecast and an analysis completed yearly. For all estimated purchases of $50,000 or more in Child Nutrition Programs, new Requests for Proposals (RFPs) will be created, or purchases will be made through a USDA-approved purchasing cooperative RFP, as applicable. New RFPswill be developed after reviewing cost estimates, product requirements, and specifications, in accordance with the approved formal procurement guidelines found in 2 CFR 200.320(b), 7 CFR Part 210.19(e), and Section 17 of the NSLP Administrator’s Reference Manual (ARM). The resulting contract awards will be annual with optional renewals and contracts will be managed and records retained per Sections 16 and 30 of the NSLP ARM to ensure compliance. Responsible Officials: Leander ISD Management Anticipated Date of Completion: November 2025

The District will review the existing capital asset listing and make changes as necessary to ensure appropriate depreciation methods are applied to capital assets currently in-service. The default settings in the capital asset management software will be reviewed to ensure ease of use in applying the appropriate depreciation methods when placing new capital assets in-service. The District will review current control processes in place over capital asset additions to ensure application of the appropriate depreciation methods.

The District assessed the investment record-keeping system and created a new spreadsheet to track investment changes more easily. The new investment spreadsheet will be updated on a periodic basis to ensure recording of investment changes.

Community Planning and Development Office of Economic Development - Congressional Grants Division – Assistance Listing No. 14.251 Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases. These procedures should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting with them, and maintaining documentation of this. The City should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases and retained with other procurement documents. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases and retained with other procurement documents. Name(s) of the contact person(s) responsible for corrective action: Benny Marcier, Mayor at 815-432-2711 Planned completion date for corrective action plan: April 30, 2026

Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for the maintenance of documentation related to procurement determinations. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

The North Sweetwater Water and Sewer District (NSWSD) Board will prepare and adopt written policies and procedures by July 2026, to ensure that all Uniform Guidance regulations, relating to SAM.gov debarment and suspension, are performed in accordance with federal regulations and reviewed on a regular basis.

The District recognizes the limited staff in the Business Office makes segregating duties virtually impossible. The Board does rely on the Business Manager to keep them updated on the financial state of the District and, due to financial constraints, does not intend to increase staffing at this time.

The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2025-2026 fiscal year.

The grant employee that was hired in this last fiscal year resigned and there was a period that it was handled by the county manager. The county has since contracted with an outside agency to handle the grants far Catron County.

Context and Cause – During the year ended June 30, 2025, OMEP entered into four first-tier subawards greater than $30,000 under AL number 11.611. The auditor tested one of these subawards, noting that the award was not yet reported under the Federal Funding Accountability and Transparency Act to the Federal Subaward Reporting System (FSRS). Per further inquiry, all of the first-tier subawards were yet to be reported to the FSRS. OMEP was aware of the FFATA reporting requirements, but the reporting was not made timely. Internal controls were not adequately designed, and procedures were not in place to track and report first-tier subawards within the time frame required by federal requirements. Recommendation – The Organization should establish written policies and procedures for reporting first-tier subawards. Action Taken: OMEP will add a fiscal policy, that includes a documented review of first tier subawards, to ensure they are input to the FSRS no later than the last day of month that follows the initial obligation to the sub awardee. Responsible parties: Controller. Anticipated completion date: June 30, 2026.

SA-2025-01 - SIGNIFICANT DEFICIENCY FINDING: During our testing of Title 1 disbursements, we noted there were multiple purchases shipped directly to a private residence without receipt of the products at the District office. All disbursements should be shipped to District property for accountability, tracking and ensuring compliance with federal regulations. When supplies are shipped to private residences, there exists the increased likelihood of errors and fraud. AUDITOR RECOMMENDATION: We recommend all disbursements be shipped to District property. PLAN OF ACTION AND TIMEFRAME FOR IMPLEMENTATION: The district acknowledges the finding and has already met with the Title 1 Coordinator and the District purchasing clerk immediately after the exit meeting with the auditors to ensure this does not occur again effective this 2025-2026 school year.

FINDING 2025-002 Procurement and Suspension and Debarment Management’s or Department’s Response: Management agrees. Views of Responsible Officials and Corrective Action: SCRRA has implemented the use of the checklist for all the required documents associated with a procurement. The checklist includes all applicable documents required to complete a procurement and communicated to the contractors. Name of Responsible Person: Cynthia Minix Implementation Date: June 30, 2026

Finding 2025-004 U.S. Department of Agriculture Federal Financial Assistance Listing/ALN #10.855 Distance Learning and Telemedicine Grants Federal Award #IA0714-BI17 2025 Procurement, Suspension and Debarment Material Noncompliance and Material Weakness in Internal Controlover Compliance Criteria: Uniform Guidance and 2 CFR §§ 200.318 through 200.326 establish the procurement standards that non-federal entities (other than states) must follow when expending federal awards. These standards require non-federal entities to maintain written procurement policies and procedures that ensure full and open competition, use of appropriate procurement methods based on dollar thresholds, and inclusion of required contract provisions as outlined in Appendix II to Part 200. Condition: The Hospital does not have a written procurement policy that conforms to the procurement standards under Uniform Guidance and 2 CFR §§ 200.318 through 200.326. In addition, testing of the Hospital’s only procurement transaction during the audit period disclosed the following instances of noncompliance: The procurement method used was not in accordance with Uniform Guidance requirements, as the contract amount exceeded the simplified acquisition threshold and a sealed bid or other allowable competitive procurement method was not obtained. The executed contract did not include all required contract provisions as prescribed by Appendix II to 2 CFR Part 200. Planned Corrective Action: Management is aware of the deficiency of internal control over the procurement, suspension and debarment direct and material requirement and subsequent to fiscal year end has implemented a formal procurement policy. Planned Completion Date: June 30, 2026 Person Responsible: Denise Hook, Chief Financial Officer

NONCOMPLIANCE WITH GRANT TERMS AND CONDITIONS; COMMUNITY DEVELOPMENT BLOCK GRANTS/STATES PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII, AL No. 14.228, GRANT No. MT-CDBG-CV-22-13, YEAR ENDED JUNE 30, 2025 Name of contact person: Jhona Peterson, City Clerk/Treasurer Corrective Action: As a general practice, the Mayor and City Council will work with the engineers and require all contractors and vendors to supply proof of suspension and debarment review prior to work contracts being finalized for all projects. Proposed Completion Date: Fiscal year 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster-Suspension and Debarment Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street. Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-003. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Corrective Action: Internal Controls regarding Procurement and Suspension and Debarment will be implemented to maintain reasonable assurance of compliance with the Procurement and Suspension and Debarment by requiring the Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Form as part of the procurement process. Once returned with the RFQ/RFP (request for quote or proposal), the Food Service Director will review with the Business Manager for approval, including both signatures. Additionally, the Business Manager will look up all vendors on the pre-approved Suspension and Debarment vendor website, and those results will be shared with the Food Service Director before the procurement process. All completed forms will be filed with the Business Manager. In addition, CN Director will provide a template letter to the vendor stating that they have not been suspended or debarred from procurement with federal entities. Vendor will be asked to sign the letter and return to the Food Service Director to keep on file at Mississinewa Community Schools. Anticipated Completion Date: January 23, 2026.

Section 223(f) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects – Assistance Listing No. 14.155 Recommendation: The Project should ensure that all inspection reports are signed by the housing manager and the tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review policies and procedures to ensure compliance is met. Name(s) of the contact person(s) responsible for corrective action: Carol Borgerson, CFO Planned completion date for corrective action plan: December 3, 2025

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our procurement for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to use our procurement process following our school board policies. NISEC has reported that for the 2023-2024 school year the corrective action plan was initiated by the below process. As a member of the Northwest Indiana Special Education Cooperative (NISEC), the School Corporation usually expends contracted services out of our general education fund. For the fiscal year of 2023-2024 we included our contracted speech services into our federal grant funds. During the audit the School Corporation was notified that we didn’t following the procurement procedures when expending out of the federal grant. This finding was due to the School Corporation not going out and receiving multiple bids for contracted companies that provide services to our students. The School Corporation uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding and discussing with the auditor we created a memo that we took to our board. In the memo we explain why we use the three contracted vendors instead of going out for bids. Finding Speech pathologist and Assistant are very difficult in the school setting and we have created great working relationships with these three contracted companies. Within the memo we list all of the contracted vendors we use and why we work directly with them instead of going out for bids. At the beginning of each school year we will take a new memo with any contracted companies that we will be using during the school year. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 31 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us Anticipated Completion Date: The Northwest Indiana Special Education Cooperative created the memo as soon as we received the finding and took the memo to the board. We have procedures in place now that any vendor that will exceed the simplified acquisition threshold, we will obtain bids or create a memo if bids are not an option. We took the memo to our October 9,2024 board. This was completed fully as of July 1, 2024. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate"

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, 2026.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, HAZARD MITIGATION GRANT PROGRAM, ASSISTANCE LISTING No. 97.039 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, 2026.

Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-023- PN01 , 25611-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Suspension and Debarment Audit Findings: Significant Deficiency Condition: An effective system of internal controls was not in place at the School Corporation to ensure the HamiltonBoone- Madison Special Education Cooperative's compliance with applicable requirements related to the Special Education Cluster (IDEA), specifically with respect to Suspension and Debarment requirements. No instances of noncompliance (entering a contract with a vendor that was suspended or debarred) were identified in the transactions selected for testing. The matter represents a deficiency in internal controls over the Suspension and Debarment process, rather than identified noncompliance with program requirements. Context: Suspension and Debarment As part of its internal control procedures, the Cooperative utilizes the System for Award Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. This verification process is designed to ensure that vendors are not suspended, debarred, or otherwise excluded from participation in federal programs, in accordance with applicable procurement regulations. Three covered transactions that equaled or exceeded $25,000 were identified. Of the three transactions, all were selected for testing, totaling $141,578. The Cooperative did not verify the vendors' suspension and debarment status prior to payment for two of the three covered transactions. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will enhance oversight of the Hamilton-Boone-Madison Special Education Cooperative's procurement process to ensure all applicable procurement steps, including suspension and debarment checks, are completed and follow federal regulations for the program, prior to entering into a contract with the respective vendor. Responsible Party and Timeline for Completion: David Hortemiller, CFO and Susan Wilson, Director of Finance met with Steven Wornhoff, Director of HBM Cooperative and Kim Kuersteiner, HBM Technology Manager to establish a process to review all vendors for suspension and debarment. Training was provided in regard to the Sam.gov website. Since August 2024, the Hamilton-Boone-Madison Special Services Cooperative (the Cooperative) has used the System for Awards Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. The Cooperative will continue to use this process for any transaction equaling or exceeding $25,000. Documentation of the verification process will be retained by the Cooperative.

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: 5/31/2026. Responsible Contact Person: Anthony Daniels-Halisi, CEO.

Congressional Directives – Assistance Listing No. 93.493 Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CAPECO will obtain time-stamped verification support from SAM.gov to ensure that potential contractors are free from debarment and suspension prior to executing the contract. Name(s) of the contact person(s) responsible for corrective action: Paula Hall, CEO and/or Katie Smith, CFO Planned completion date for corrective action plan: Effective Immediately