Corrective Action Plans

2025-001 – FosterHub did not have a process to determine if vendors were suspended or debarred from receiving federal funds Auditor’s Recommendation: It is recommended that FosterHub develop and implement a suspension and debarment procedure to review the eligibility of vendors before entering into contracts. Training should be provided to all relevant staff to ensure awareness and compliance with federal requirements. Additionally, periodic monitoring and internal audits should be conducted to ensure adherence to the established procedures. Views of Responsible Officials and Planned Corrective Actions:Management acknowledges the finding and agrees with the recommendation. FosterHub has already developed and implemented a formal suspension and debarment procedure in early 2026. Training sessions have been conducted for all procurement staff to ensure understanding and compliance with the new procedure. Furthermore, periodic reviews will be instituted to monitor adherence to these requirements and to prevent the recurrence of this issue.

Significant Deficiency in Internal Control over Compliance and Compliance – Procurement, Suspension and Debarment Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management reinforce procedures to ensure that verification of procurement, suspension and debarment practices are performed and documented prior to entering into any covered transaction or subaward. This may include retaining screenshots from SAM.gov, signed certifications, contract clauses confirming compliance, and documentation of competitive pricing retained for records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The policies and procedures associated with this process will be improved per the audit recommendations and then training for all staff involved will be completed. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026

Documented Policies and Procedures related to Suspension and Debarment Recommendation: ICHCA should implement formal written policies in compliance with suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: ICHCA staff were provided a refresher on suspension and debarment documentation requirements, and policies and procedures were updated to emphasis the need to retain documentation of exclusion and debarment inquiries. Personnel have been filing documentation with contracts as of April 2026. Name(s) of the contact person(s) responsible for corrective action: Kyle Rooks, CEO Planned completion date for corrective action plan: April 2026

Views of Responsible Officials: Each screening is uploaded with the first payment request to any vendor, supplier, or consultant. The Foundation will retroactively document the date the screening was conducted, the date the screening was reviewed, as well as the name of the person performing the review of the screening for all vendors, suppliers, or consultants that were paid during FY26. Going forward, the date the screening was performed, along with the person reviewing the screening and the date of that review, will be documented. The Foundation performs new screenings annually for all vendors, suppliers and consultants at the beginning of the fiscal year.

Procurement, Suspension, Debarment Description of Finding: The Board of Education failed to document their review of suspension and debarment status prior to awarding contracts to vendors. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will review existing processes and contracts to ensure procurements are taking place in compliance with local policies and federal guidance. Name of Contact Person: Rita Parciak, Director of Finance, Groton Public Schools Projected Completion Date: June 30, 2026

Finding 2025-002 – Suspension & Debarment (Significant Deficiency in Internal Control Over Compliance) Planned Corrective Action: Following the prior year’s audit, Finance completed a full review of all vendors exceeding the threshold in 2024 and obtained the required documentation. The vendor identified in 2025 was not included in that review because it did not exceed the threshold in 2024. The actions above are designed to ensure vendors are captured based on current-year activity. Seattle Indian Health Board will implement the following specific actions to ensure compliance with Uniform Guidance requirements: - Require a documented SAM.gov suspension and debarment check for all vendors prior to contract execution and once cumulative spending limits exceeds $25,000, regardless of prior year activity. - Require completion and retention of either a competitive bid summary or a written sole source justification for all covered transactions. - Perform a quarterly review of vendors with spend over $25,000 to confirm documentation is complete. Name of Responsible Party: Brian Jonas, Controller Anticipated Completion Date: September 30, 2026

Item: 2025-001 Assistance Listing Number: 93.185 Program: Immunization Research, Demonstration, Public Information and Education Training and Clinical Improvement Projects Federal Agency: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: NH23IP922665 Award Year: August 2024 to July 2029 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Name of Contact Person: Rebecca Coyle, Executive Director Phone Number: (202) 552-0208 Anticipated Completion Date Completed April 2025 Views of Responsible Officials and Corrective Actions: In April 2025, a standardized procurement checklist and a formal review process were established and are maintained to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds.

Management's Response: The School District concurs with the recommendation. We recognize the importance of maintaining strong internal controls to ensure that all procurement activities are conducted in full compliance with Uniform Guidance (2 CFR Part 200) requirements. To address this recommendation, the District will enhance its existing procurement procedures by: 1. Developing and Formalizing Written Internal Controls. 2. Implementing Staff Training. 3. Strengthening Monitoring and Review Processes.

Action Taken: The Jericho Project (Jericho) understands the findings outlined in the audit report. Jericho has updated its procurement procedures for the federal grant to align with 2 CFR section 200.213 and 2 CFR section 180.300. To ensure that vendors supporting efforts on the federal grant are not suspended or debarred from doing business with the federal government, Jericho has added a task in our Procurement Summary (procurement checklist) that specifically requires the project manager and CAO to verify the vendor's eligibility in the System for Award Management ("SAM") maintained by the General Services Administration ("GSA") (available at SAM.gov). In addition to the verification that the vendor is NOT prohibited (debarred or suspended) from providing services to or contracting with the United States government, Jericho will retain a copy of the verification for the procurement file. This action will be completed during the vendor evaluation stage of the procurement and before contract is awarded to the vendor It should be noted that the vendors selected for testing for 2025 were found to be in good standing. Expected completion date: Corrective Action incorporation has already begun and will be fully implemented by 6/30/2026.

Jordan Kramer Chief Financial Officer 202-624-7787 January 2024 Management's Corrective Action Plan: NGA has previously developed and communicated our procurement processes and procedures to all staff members. We will provide additional training for employees involved in sourcing decisions during meetings, focusing on the accurate documentation of decision-making processes. In response to this finding, NGA will review the vendor selection processes for events over the past six months to ensure appropriate documentation is captured in the finance system. Ongoing training will be provided to new program staff regarding procurement documentation requirements to maintain compliance with established policies. When circumstances necessitate working with a specific entity or time constraints preclude a competitive process, program leaders and finance will collaborate to produce a memorandum detailing the work’s unique requirements and the criteria underlying vendor selection. Additionally, the CFO will coordinate with management to notify supervisors when procedures are not followed and to pursue corrective actions, ensuring all individuals complete the necessary compliance steps. The NGA Management Team deeply values the partnership with its Baker Tilly auditors as we address these concerns. Your expertise and guidance are crucial to our improvement process. Please ask any questions or provide feedback on management's action plans.

Finding 2025-004 Federal Departments: Corporation for National and Community Service Assistance Listing #: 17.274 Internal Controls Material Weakness Category of Finding – Procurement, Suspension, and Debarment Finding Summary: There was no observable control documentation to directly indicate that a search for suspension and debarment was performed on vendors. Responsible Individuals: Jill Johnson, Executive Director Corrective Action Plan: Our Executive Director and Controller developed an updated procurement policy that went into place July 1, 2024. Our Operations Manager did not follow the policy. This staff member is no longer with the organization. We have implemented new training for managers and directors about the procurement policy to ensure proper execution going forward. Anticipated Completion Date: July 1, 2025

Suspension and Debarment Recommendation: We recommend that the Town reinforce the consistent execution of its existing suspension and debarment procedures to ensure that vendors are verified as not suspended or debarred prior to contract execution or the processing of program-related expenditures. In addition, the Town should consistently retain documentation evidencing the timely performance, review, and approval of suspension and debarment checks for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will strengthen the consistent execution of its suspension and debarment controls. All vendor eligibility checks will be required to be completed, reviewed, and approved prior to contract execution or the processing of program-related expenditures. Review and approval will be evidenced through a dated "Received" stamp or similar documentation applied by the Assistant Town Administrator and retained in the vendor file. Management will also perform periodic monitoring to ensure that suspension and debarment controls are applied consistently. Name of the contact person responsible for corrective action: Tyler Home, Director of Finance. Planned completion date for corrective action plan: March 31, 2026

We agree with the auditor's comments. While we have retroactively searched for suspension and debarment, not all subrecipients were able to finalize their registration on SAM.gov. We determined that 7 of the 27 recipients were confirmed to have no suspension or debarment, totaling $514,450 of the grant total. Our office of Law has drafted and amendment to the agreement that requires the subrecipient certify that they have not been suspended or debarred. We will have each subrecipient sign the amendment. We anticipate completion of this by March 31, 2026.

Coronavirus State & Local Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College verified the status of all vendors utilized in federal grant disbursements during the year ended June 30, 2025. A spreadsheet was maintained during that year which documented this. Since June 30, 2025, a procedure has been added to retain copies of the sam.gov verifications for additional documentation. Name(s) of the contact person(s) responsible for corrective action: Susan Spencer, Vice President for Finance Planned completion date for corrective action plan: Completed March 2026 If the United States Department of Treasury has questions regarding this plan, please call Susan Spencer at 660-263-4100, ext. 11274.

2025-005 – Procurement, Suspension and Debarment Corrective Actions – Sheridan County Issue: The Weed & Pest District does not have formal, written policies or procedures governing procurement activities, including required methods of procurement, documentation standards, and approval thresholds. Additionally, the Weed & Pest District lacks documented procedures to verify and document that vendors are not suspended or debarred prior to entering into contracts or making payments using federal funds. Corrective Action: Management agrees with the finding and plans to develop and formally adopt procurement and suspension and debarment policies. Implementation is expected to occur during the next fiscal year. Implementation of Corrective Action: All Weed & Pest federal award grants will be sent to the County Administrative Director for review. Suspension and debarment language, including required lower tier transaction verification requirements shall be added to all Weed & Pest contracts which are funded through Federal Awards as follows: • Suspension and Debarment, Voluntary Exclusion. By signing this Contract, ______________ certifies that it is not suspended, debarred, or voluntarily excluded from Federal financial or non-financial assistance, nor are any of the participants involved in the execution of this Contract suspended, debarred, or voluntarily excluded. Further, _____________ agrees to notify Sheridan County Weed & Pest by certified mail should _____________ or any of its agents or subcontractors working on this project become debarred, suspended or voluntarily excluded during the term of this Contract. Weed & Pest will conduct a search of the System for Award Management (SAM.GOV) to determine if the bidding entity has been suspended or debarred from participating in Federal award contracts. A copy of the SAM.GOV certification will be required from contractors prior to final Weed & Pest award of contract.

Name of Contact Person Anna Kinder, Casper Natrona County Department of Health, Executive Director Board of County Commissioners Corrective Action Plan Management agrees with the finding and plans to adhere to compliance with suspension and debarment policies including documentation requirements. Implementation is expected to occur during the next fiscal year. Proposed Completion Date June 30, 2026

We have reviewed the findings and recommendations in the audit for Fiscal Year 2025. The following are our planned corrective actions for the identified issues: Finding 2025-002: Procurement Procedures. - Change in procedure for Treasurer review of contract awards when presenting to Council to include checking vendor for suspension or debarment and document. - Update pruchasing policies and procedures to add requirement to check for vendor suspension or debarment prior to contract award. We appreciate the constructive feedback provided by your firm which provides us with the opportunity to improve and grow.

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

The Administrative Services Office will add an implementation process note to the College’s Administrative Policy 6.03 as well as in the Business Office’s Procedures Manual outlining a new Debarred and Suspended Parties Process. The new process will read as follows: To ensure that Central Wyoming College is not conducting business with vendors who have been suspended or debarred from conducting business with the Federal government, a department should check the vendor against the EPLS before creating a payment request or making a payment equal to or exceeding $25,000. The Principal Investigator (PI) or designee checks the vendor on www.sam.gov. The PI or designee will document the Suspension and Debarment verification by including a screen print of the Exclusions search in the grant file with a copy to the Grants Management Specialist and a copy to the Business Office with a W-9, if it’s a new vendor. For individuals or vendors that are found to be suspended or debarred, the PI or Grants Management Specialist will notify the Business Office to flag the vendor in Colleague alerting the person entering the voucher that they may not pay this vendor with Federal funds. Semi-annually the Grants Management Specialist will run a list of all vendors and employees paid from Federal funds over $25,000. Anticipated Completion Date: December 1, 2025 Contact Person(s): Willie Noseep, Vice President for Administrative Services

Reference Number: 2025-004 Description: Procurement Corrective Action Plan: The District will ensure that suspension and debarment certificates are obtained for all necessary vendors. If Certificates are not available, the District will search Sam.gov prior to doing business under a covered transaction. Contact Information: For additional information regarding this finding, please contact Ryan Bandt, Director of Business Services, at 920-675-1044.

All covered contractors will be checked in SAM.gov and any required recoveries will be addressed; procurement policy will be updated to require formal exclusion screening and certification for SLFRF-related contracts; procurement and program staff will receive training on suspension/debarment rules; and an annual compliance checklist will be implemented to confirm all future covered transactions include exclusion checks.

Finding 2024-007: Procurement and Suspension/Debarment Documentation and Record Retention – Material Weakness Condition: NACA has written procurement policies that comply with Uniform Guidance; however, documentation evidencing compliance with procurement procedures and suspension and debarment requirements was not consistently retained. Corrective Action: Management will enhance implementation of existing procurement policies by ensuring that documentation supporting procurement decisions and suspension and debarment checks (e.g., SAM.gov verification) is consistently retained for applicable transactions. Procedures will be reinforced to ensure appropriate documentation is maintained for audit and monitoring purposes. Name of Person Responsible: Walter McCullough, CFO Anticipated Date of Completion: May 31, 2026

The district will create an SOP for procurement activities moving forward as well as making sure to train staff responsible for procurement to ensure compliance with Federal compliance.

2024-001 – The Organization did not have a process to determine if vendors were suspended or debarred from receiving federal funds Auditor’s Recommendation: It is recommended that FosterHub develop and implement a suspension and debarment procedure to review the eligibility of vendors before entering into contracts. Training should be provided to all relevant staff to ensure awareness and compliance with federal requirements. Additionally, periodic monitoring and internal audits should be conducted to ensure adherence to the established procedures. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and agrees with the recommendation. FosterHub will develop and implement a formal suspension and debarment procedure within the next three months. Training sessions will be conducted for all procurement staff to ensure understanding and compliance with the new procedure. Furthermore, periodic reviews will be instituted to monitor adherence to these requirements and to prevent the recurrence of this issue.

Views of Responsible Officials: During FY2025-2026, CASA expanded and operationalized its procurement policy and process. Implementation included conducting SAM checks and requiring vendor certifications of good standing prior to selection. These steps are essential to ensuring we engage qualified, compliance vendors and consultants.