Corrective Action Plans

While reviewing the City of Pueblo Schedule of Expenditure of Federal Awards (SEFA), the auditors found that there were subrecipient awards of Federal funding of CDBG and HOME programs, that met the criteria for FFATA reporting, that were not reported. Management acknowledges fault in reporting subrecipient awards. The primary cause was lack of awareness of FFATA criteria in reporting requirements. To address these issues, management will ensure staff is trained in reporting criteria and that all reporting is completed within 30 days as required.

Finding No.: 2024-002 For procurements using federal funds, GMHA is permitted to use a Simplified Acquisition Threshold up to the federal limit, which is currently set at $250,000 or $7.5 million for commercial goods. The Code of Federal Regulations (CFR) permits a non-federal entity to use a SAT up to the federal limits, without having to follow threshold limitations imposed by state or local law. The set of criteria employed by the Ernst & Young is incomplete, and fails to give proper deference to the legal opinions of licensed attorneys. In determining to follow the federal SAT, GMHA considered the guidance of a memorandum from the Office of the Attorney General indicating substantively the same legal analysis as follows. See Memorandum from Deputy Attorney General, Solicitor Division to Chief Deputy Attorney General, Federal Simplified Acquisition Threshold and Micro-purchase Threshold, Ref: AG 22-0410 (Sept. 14, 2022). When presented with this memorandum, the auditors refused to accept its instructions stating: “We were unable to follow why the Attorney General considered the definition of a non-Federal entity in applying the requirements of §§ 200.318 through 200.327. In reviewing the aforementioned sections, there was no reference to non-Federal entities.” This statement evidences the auditors’ fundamental misunderstanding of the law. The auditors based their analysis on an amended version of the CFR, which became effective only January 2025. According the definitions in the Code of Federal Regulations in effect during the relevant 2023-2024 audit period, Guam is both a “State” and a “Non-Federal entity.” Guam Memorial Hospital Authority also falls within the definition of “Hospital” and “subrecipient.” As relevant here, 2 CFR 200.1 states: State means any State of the United States, the District of Columbia, the Commonwealth of Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments. Non-Federal entity (NFE) means a State, local government, Indian Tribe, Institution of Higher Education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient. Hospital means a facility licensed as a hospital under the law of any State or a facility operated as a hospital by the United States, a State, or a subdivision of a State. Subrecipient means an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a Federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. As a Non-Federal entity, GMHA also is required to abide by the definition of “simplified acquisition threshold.” According to 2 CFR 200.1: Simplified acquisition threshold means the dollar amount below which a non-Federal entity may purchase property or services using small purchase methods (see § 200.320). Non-Federal entities adopt small purchase procedures in order to expedite the purchase of items at or below the simplified acquisition threshold. The simplified acquisition threshold for procurement activities administered under Federal awards is set by the FAR at 48 CFR part 2, subpart 2.1. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. However, in no circumstances can this threshold exceed the dollar value established in the FAR (48 CFR part 2, subpart 2.1) for the simplified acquisition threshold. Recipients should determine if local government laws on purchasing apply. (emphasis added). This definition applies to purchasing by all non-federal entities—including GMHA. Title 2 CFR 200.317 provides: When procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds. The State will comply with §§ 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by § 200.327. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in §§ 200.318 through 200.327. (emphasis added). As a subrecipient of Guam, GMHA would also be required to follow 2 CFR 200.320(a)(2)(ii), which reiterates that: “The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR.” The CFR treats the requirement that a state or local entity follow (1) its own “policies and procedures” and (2) its own small purchase “threshold” as separate requirements. The CFR applicable to most federal funds—including ARPA—only requires the hospital to follow the local “policies and procedures.” 2 CFR 200.317. The CFR requires GMHA—as a non-federal entity—to separately make a determination of an appropriate small purchase threshold based on a number of factors specific to GMHA, provided it does not exceed the federal SAT. 2 CFR 200.1; 2 CFR 200.320(a)(2)(ii). Procurement method selection is essentially a two-step process: (1) Make a substantive determination about the monetary cost of a proposed procurement and determine whether it is below or above an applicable threshold. Which side of a threshold a procurement falls on (and some other factors) will determine the method—sole source, RFQ, RFP, IFB—that will be used. (2) After the method is determined, an entity is then pointed to specific policies and procedures applicable to that type of procurement. The relevant factors for determining a recipient-specific SAT include an entity’s “internal controls, an evaluation of risk, and its documented procurement procedures.” 2 CFR 200.1; 2 CFR 200.320(a)(2)(ii). For a portion of the relevant procurement period, the CFR also stated: “When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations.” This section was amended effective approximately October 1, 2024. Now, it no longer requires the recipient or sub-recipient to ascertain whether this entity-specific threshold is “authorized or not prohibited under State, local, or tribal laws or regulations.” But even under the prior version, the entity only needed to consider the authorization or lack of prohibition under state or local law if it was adopting a “lower simplified acquisition threshold” than the federal SAT. 2 CFR 200.320(a)(2)(ii) (effective until Sept. 30, 2024) (emphasis added). GMHA determined that the federal SAT levels were appropriate, and—in any event—local law does not prohibit GMHA from adopting the federal SAT when using federal funds. GMHA’s use of the federal SAT for procurements using federal funds has been a decades long practice of our materials management, so a suggestion that it is unauthorized would be a finding quite inconsistent with GMHA’s internal controls. Highlighting the distinctness or difference between the “policies and procedures” and “threshold” requirements, is the fact that “simplified acquisition procedures” and “simplified acquisition threshold” are defined separately. See 48 CFR 2.101. And the two requirements are discussed separately in the section of the CFR discussing “informal procurement methods.” 2 CFR 200.320. Additionally, the small purchase “procedures” applicable to federal agencies, FAR Part 13, are contemplated in an entire section that is separate from the rules about the controlling SAT or other threshold. Finally, in other portions of the CFR—such as federal highway funds—the government has specifically instructed state entities to follow both the state or local “procedures” and the state or local “threshold. 23 CFR 172.7(a)(2). When the CFR wants the state government to follow state SATs, it will specifically do so. It has not put that instruction in 2 CFR 200.320. Guam law also specifically directs all persons within the Government of Guam to comply with the applicable federal law and regulations that are in conflict with or are not reflected in the Procurement Code. 5 GCA § 5501. In other words: Guam law requires GMHA to follow the federal rules. Specifically, here, the federal requirement that GMHA determine an appropriate SAT is not reflected in the local laws. GMHA, thus, must comply with the federal requirement that GMHA make a recipient-specific determination of an appropriate SAT. Even the Guam Legislature understands that the law operates in the same manner as the Attorney General’s memorandum. During a legislative hearing on June 25, 2024, Senator Sabina Perez recited the same analysis, recognizing that Guam agencies can use the federal simplified acquisition threshold when expending federal funds. See Guam Legislature, Public Hearing Bill No. 134-39 (COR) at *1:46:00-1:46:31 (June 25, 2025), available at https://www.youtube.com/live/ciXo1EEXJZI. In deciding the federal SAT applies, GMHA was also guided by precedent and guidance issued to other government entities. In 2015, when the Guam Department of Education was under a federal third-party fiduciary, it was still employing the lower local small purchase threshold. GDOE was instructed that this was inappropriate because federal law supersedes Guam law on the SAT. The federal fiduciary—consistent with USDOE instructions—required GDOE to follow the federal SAT. See Letter from John E. Hampford, Alvarez & Marsal, to Jon J.P. Fernandez, Superintendent of Guam Department of Education (Dec. 30, 2015); see also Letter from Jon J.P. Fernandez, Superintendent of Guam Department of Education to Attorney General Leevin T. Camacho and Public Auditor Benjamin J.F. Cruz (July 20, 2020). Thus, other Guam agencies have been instructed by the federal government to use the federal SAT. This is also bolstered by the case law. The Guam Supreme Court has ruled that the CARES Act funding was a federal appropriation for a specific purpose, “outside the control of the Guam Legislature.” See Story-Bernardo v. Gov’t of Guam, 2023 Guam 27 ¶ 46. ARPA funding is substantively similar to CARES Act funds, simply with additional permitted uses. Local law cannot dictate how these federal funds are spent. GMHA also considered case law from Texas federal court where a self-styled “whistleblower” sued the City of Burleson, Texas for allegedly spending in excess of their own SAT. Under Burleson’s own regulations, the local SAT was $10,000, see Rule 5.1, City Council Policy 36, City of Burleson Purchasing Policy (adopted July 2, 2018, revised Oct. 16, 2023). However, the lawsuit alleged that the city was spending in excess of this $10,000 SAT. The federal judge in that court stated: “In addition, the regulations show that “formal purchasing methods are not required” for purchases that are less than the “simplified acquisition threshold.” 2 C.F.R. § 200.1(2021). The simplified acquisition threshold is set at $250,000. 48 C.F.R. § 2.101(2021). However, Mr. Eder's complaint incorrectly alleges “upon information and belief” that the simplified acquisition threshold is $10,000. Doc. No. 37 at 12, ¶27(b). Mr. Eder's apparent misreading of the threshold for formal purchasing is central to his claim under the FCA, and it appears this concern may have arisen from simply misreading the rules, rather than any reasonable dispute under the law.” Eder v. City of Burleson, Civil No. 3:23-CV-00948-K, 2024 WL 4771408 at *5 (N.D. Tex., Nov. 13, 2024). Thus, the federal court recognized that the lower local SAT did not control. The only relevant SAT was the federal one. GMHA’s determination to use the maximum SAT allowed by the federal CFR is thus appropriate. The federal CFR rule requiring a recipient-specific SAT determination supersedes the local thresholds. If the procurement is under the federally-allowed $250,000 SAT, GMHA must still follow the local small purchase procedures. See in part 5 GCA § 5213. The auditors’ view of Guam law appears to be a clear outlier, inconsistent with a plain reading of both federal and Guam law, the opinions of both federal and local courts, the memorandum from the Attorney General’s Office, the understanding of the Guam Legislature, and the reasoned opinion of Hospital Legal Counsel. The auditors’ finding is also inconsistent with decades of GMHA procurement practice. The questioned costs based on this finding should be removed. The auditors’ (1) inability to even reference the relevant definitions from the CFR in effect at the time of the relevant audit period and (2) unwillingness to accept the legal opinions from licensed attorneys, should be a finding on the auditors’ peer review.

FINDING 2024-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: David M. Kennard Contact Phone Number and Email Address: 812-677-3959 clerk@princetoncity.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerk-Treasurer will prepare the Project and Expenditure report and someone else, who is knowledgeable about the awards and the reporting compliance requirement, will review the report prior to submission. Documentation of the review will be retained with the City’s records. Anticipated Completion Date: The corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement Contact Person Responsible for Corrective Action: David M. Kennard Contact Phone Number and Email Address: 812-677-3959 clerk@princetoncity.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will establish a proper system of internal controls to ensure expenditures made from federal awards use the appropriate procurement method and retain the documentation to support the procurement methods used in order to ensure compliance with the terms and conditions of the federal awards. Anticipated Completion Date: The corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Fund – Reporting Contact Person Responsible for Corrective Action: Annette Phillippo Contact Phone Number and Email Address: 765-472-3901, ext. 1240 and aphillippo@miamicountyin.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Verify by a second person in Auditors that reports are accurate and sent to treasury quarterly. Anticipated Completion Date: Completed before 09/22/2025 Submitted by: Annette Phillippo Miami County

Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: The Grant Administrator will monitor all claims that will be used for the quarter and send them to the reporting agent to report after the quarter ends. She will be diligent to track any claims coming in outside of that quarter so that reporting is accurate. She will provide the reporting agent with all claims relevant to that quarter’s report. Anticipated Completion Date: This will be done quarterly starting with the quarter ending on September 30th, 2025. The Grant Administrator will submit these claims to the reporting agent one week after the quarter ends. The Financial Administrator will sign o􀆯 on the LOW report to verify the claims match.

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corrective Action: We concur with the finding. Description of Corrective Action Plan: The annual reporting for fund 8950 – Coronavirus State and Local Fiscal Recovery Funds with the Treasury shall be prepared by the First Deputy, reviewed by an independent accountant to verify and consult that all the information is correct, and the final report will be reviewed and approved by the County Auditor before submission. Anticipated Completion Date: Next annual reporting Due April 30, 2026 for 2025

FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025

Federal Award Finding: 2024-001 Material Weakness in Internal Control over Cash Management Name and Contact Person: Laurie Stuart, Executive Director Corrective Action: The Organization has evaluated and revised the processes and procedures regarding cash management and reporting, in efforts to minimize the time elapsing between the transfer of funds from the awarding agency and disbursement by the Organization. The Organization also has processes in place for maintaining detailed records supporting all grant payments, disbursements to vendors, and tracking of grant advances still outstanding. Additionally, the Organization is monitoring interest earned on grant advances and has processes in place to remit interest as appropriate when required in accordance with Uniform Guidance. Management has appointed an individual to oversee these processes for each grant. Management will also submit a revised annual financial report [FFR] for USFWS Agreement No. F23AC02320 to correct any errors related to cash on hand amounts reported. Proposed Completion Date: December 31, 2025

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Additionally, Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025

Finding 2024-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Contact Person Responsible for Corrective Action: Cindy Poore Contact Phone Number and Email Address: 317-733-2809, cpoore@zionsville-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Below is the process for submitting required grant reporting. 3. The Director will input the required information 4. Prior to submission of the report, the Director will have the Deputy Director verify the information that has been entered against the supporting documentation. 5. The Deputy Director will let the Director know if it is ok to submit the report. 6. The Director will submit and print a completed submission document that the Deputy Director will verify again. 7. The Deputy Director and Director will both sign and date the completed report. 8. This will be filed for audit purposes. Anticipated Completion Date: This is already taking place. The 2025 filing in April followed this process.

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material weakness, Modified Opinion The information submitted included amounts based on the incorrect period, amounts that should have been omitted, and amount which were based on budgeted amounts instead of actual amounts, as such the reports were not fairly presented. Errors identified included the following: • Total Cumulative Expenditures were overstated by $3,174,098 • Total Current Expenditures were understated by $616,514 • Total Current Obligations were overstated by $1,825,902 Additionally, The County was unable to provide documentation to substantiate the amount obligated to one vendor used for the Government Services project. Contact Person Responsible for Corrective Action: Britt Ostler Contact Phone Number and Email Address: 765-659-6330/bostler@clintoncountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Auditor unfortunately didn’t have the guidance from the SBOA until after the P&E report was submitted for 2024. The Auditor did take tremendous care to create a spreadsheet to make sure expenditures were reported in the correct time periods for 2025. The First Deputy reviewed the timeframe and expenditures as well to ensure we had several sets of eyes on the documentation before submitting the P&E report. We will have both the Auditor and First Deputy create the spreadsheet and review before submitting. Anticipated Completion Date: December 31, 2025

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Wendy Marples Contact Phone Number and Email Address: 812-338-2142/ auditor@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The County Auditor will ensure that any future ARPA funding will be reported correctly and broken out by project. This will also be verified with the ledger for the same period. Internal controls within the office will ensure the County Auditor reviews everything is correct prior to submission. Anticipated Completion Date: December 31, 2025

FINDING 2024-004: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The town attorney will draft a standard contract that will apply to any contractors that are paid $25,000.00 or more from federal funds, prior to entering a covered transaction ensuring that their respective contractor is not suspended or debarred. The council president will review and sign the contract ensuring the suspension and debarment clause is included in all respective contracts. The town has put controls and procedures in place to ensure timely documentation of suspension and debarment checks in regard to federal awards. For purchases procured outside of a contractual agreement, the town will require all vendors to self certify prior to entering into a transaction. The town will implement a procurement policy that conforms to the current requirements of CFR 200.318 for micro-purchases, under $10,000.00, the disbursing officer will only require board approval. For small purchases, between $10,000.00 and $150,000.00, three quotes must be obtained and a contract awarded. For purchases that exceed the simplified acquisition threshold, the town must allow for full and open competition in the form of a sealed bid process and awarding a contract. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

FINDING 2024-003: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In regards to the current finding over the reporting period under audit all pertinent issues will be corrected in the following annual project and expenditure report, due in April, 2026. The town will contract with Local Government Services to prepare the annual project and expenditure report, develop a procedure where the Clerk-Treasurer or any Town employee with proper training and knowledge will review the report prior to submission for accuracy and completeness before final filing. The Clerk-Treasurer or respective town employee who will review the report, will receive the proper training over the respective program. Any correspondence between Local Government Services and the Town of Ridgeville will be documented accordingly. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

August 20, 2025 FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Martha L. Arnold-Turner Contact Phone Number and Email Address: 812-275-3111, mturner@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county corrective action plan will be designed to implement a proper system of internal controls that will ensure compliance with the Reporting requirements of the grant. - The County will implement internal controls that will prevent or correct noncompliance. For all Federal grants that require reports, after one person prepares the report, another person will review the report for accuracy and completeness prior to it being submitted. Anticipated Completion Date: 12/31/2025

Planned Corrective Action: The District is in the process of reviewing and updating controls to ensure payments for construction services are made timely and consistently. The District is requesting a refund from the vendor. Anticipated Completion Date: October 1, 2025 Responsible Contact Person: Marleni Bruner

FINDING 2024-003 (prior finding audit number 2023-002) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: One person will complete the report and another will sign off on a full review. Anticipated Completion Date: April 1, 2026 (based on due date of the next report)

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Jessica Secrease, County Auditor Contract Phone Number and Email Address: 765-456-2804 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To prevent a recurrence of this issue in future audits, the County will implement a new internal control procedure. Specifically, the Auditor’s Office will require that both the Deputy Auditor and the County Auditor review and sign off on all Coronavirus State and Local Fiscal Recovery Fund reports prior to submission. This dual-review process will include a standardized checklist to verify data accuracy, consistency with supporting documentation, and compliance with federal reporting requirements. In addition, staff involved in the preparation of the reports will receive refresher training on the applicable guidance and reporting protocols to ensure a thorough understanding of expectations and requirements Anticipated Completion Date: September 2025

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lori Elmore Contact Phone Number and Email Address: 317-325-1315 Lelmore@greenfieldin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure an internal person reviews the items included in the Annual Project and Expenditure Report before the submission of the report, we will implement a system where communications are exchanged between the Clerk-Treasurer and the person reviewing the submission to verify the report has been reviewed by someone other than the preparer. The spreadsheet which tracks expenditures has been amended to separate the reporting periods. Anticipated Completion Date: By April 30th, 2026 when the next Annual Project and Expenditure Report is due to be submitted.

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, repo1ting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Shelly Baucco, County Auditor Contact Phone Number and Email Address: (260) 563-0661 Views of Responsible Officials: We concur with the finding and submit the following corrective action plan. Description of Corrective Action Plan: 1. The Auditor will print reports in the date span of the reporting period. 2. The Auditor will fill out the SLFRF Compliance Report and print it out for review. 3. A Deputy Auditor will compare the report documents to the Compliance report from SLFRF with checkmarks, for date span and correct amounts reported. Then sign off when correct and completed. 4. The documentation will be filed in the Grant binder. Anticipated Completion Date: August 2025