Corrective Action Plans

Management concurs with the finding and recognizes the importance of ensuring that all procurements utilizing federal funds comply with applicable suspension and debarment requirements. To address this finding, management will strengthen its procurement procedures to require verification that all vendors, sub-recipients and contractors receiving federal funds are not suspended, debarred, or otherwise excluded from participation in federal transactions prior to entering into a contract or issuing an award. For each applicable procurement, the Organization will document verification of the vendor's eligibility by performing a search of the federal exclusions database at SAM.gov or by obtaining an appropriate certification from the vendor. The Organization will retain documentation of the verification with the related procurement and contract records in the form of a screenshot or pdf of the SAM.gov database search. Where appropriate, contracts will also include a suspension and debarment provision. Management will incorporate this verification step into the Organization's contract and procurement review process and will provide guidance to personnel responsible for federal procurements regarding the requirement. The Grant Financial Manager will verify that the suspension and debarment check has been completed and documented before the procurement is finalized. Management believes these corrective actions will strengthen internal controls and reduce the risk of entering into contracts with entities that are suspended, debarred, or otherwise excluded from participating in federally funded transactions. Responsible Party: Renee Kempka Anticipated Completion Date: 09/15/2026

2025-005 – Finding: Material Weakness in Internal Controls over Compliance and Noncompliance: Procurement, Suspension, and Debarment Responsible official: Rose Braden, President Context and Cause: SEC’s current procedures and policies did not include a review of contractors for debarment. Recommendation: Management should establish, document, and implement procedures requiring that contractors be reviewed for debarment as part of the contract approval process. Corrective Action Planned: SEC will update processes and policies. A documented review for debarment will be added to contractor review procedures. Implementation date: December 31, 2026

Finding Number: 2024-001 Recommendation: Create a procurement policy that meets the requirements detailed in 2 CFR 200.318– 200.327 Action Taken: AANA will implement a new Procurement Policy as it relates to purchases and grants supported by the MAST program. See document “MAST Procurement Policy” Responsible Contact Person for Planned Corrective Action: Dennis Siena Anticipated Completion Date: September 30, 2025

The Organization will review its procurement procedures to ensure they include performing and documenting the appropriate searches. The Organization accepts the recommendations.

UCCAC will incorporate checklist to ensure that before entering into a contract or securing services with a vendor they are verified against SAM.gov exclusion database. Evidence of verification will be retained on file. Responsible Person: Executive Director, Program Directors and Controller Timeline: 0-30 days

Audit Recommendation: The Organization should search federal database to ensure vendors paid using federal funds are not suspended or disbarred. Planned Corrective Actions: The Organization will review its procurement procedures to ensure they include performing and documenting the appropriate searches. The Organization accepts the recommendation. Anticipated Completion Date: June 30, 2025 Contact Person: Helen Gates, Accounting