Corrective Action Plans

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.

Suspension and Debarment Description of Finding: The Town did not have the proper controls in place to ensure vendors were not suspended or debarred in accordance with 2CFR section 200.213. Statement of Concurrence or Nonconcurrence: The Town concurs. Corrective Action: The Town of Hebron will design controls to ensure adequate documentation exists that the Town reviewed potential contractors to determine they are not suspended or debarred in accordance with 2 CFR Section 200.213 before the contracts are executed or services rendered. We have added a debarment certification in our bid documents and will update the Purchasing Policies to include specific language regarding 2 CFR Section 200.213. Name of Contact Person Donna Lanza, Interim Town Manager Projected Completion Date June 30, 2027

Person responsible for corrective action plan: Stacey Mike, Interim Tribal Chair Marjianne Yonge, Tribal Treasurer PO Box 747 Lone Pine, CA 93545 (760) 876-1037 Condition: During testing, we noted the following: 21.027 • 5 of 6 IIIs did not have documentation of alternate bidding or sole source justification. • 6 of 6 IIIs did not have documentation that a suspension and debarment search was performed prior to purchasing. 93.445 • 7 of 7 IIIs did not have documentation that a suspension and debarment search was performed prior to purchasing. Corrective Action: Suspension and debarment procedures will be documented by the fiscal staff prior to paying any new contractors. Bidding and or sole source justification shall be documented and provided to the fiscal staff prior to the payment being issued. Anticipated date of completion: November 30, 2026.

The City will implement a new policy to verify vendors are not suspended or debarred.

Finding 2024-004: Procurement and Suspension and Debarment (Title V, CFDA 93.U01) Material Weakness (Repeat Finding: 2021-004, 2022-004, 2023-004)Condition: Because Title V expenditures lacked transaction-level detail, the auditor could not select procurement transactions for testing or verify that vendors were screened for suspension/debarment prior to contract award. Corrective Action: • Adopt a written procurement policy aligned with Uniform Guidance thresholds (micro-purchase, simplified acquisition, formalprocurement); this policy is in progress and pendingboard approval. • Require and document a System for Award Management (SAM.gov) check, or an equivalent vendor certification, before anyfederally funded contract or purchase order is issued. • Retain SAM.gov screening printouts/certifications with the procurement file for each Title V vendor. • Apply the GLrestructuring from Finding 2024-003 so procurement transactions are individually identifiable for testing. Responsible Party: Chief Financial Officer Anticipated Completion Date: Procurement policy adopted by November 15, 2026; SAM screening process in effect for all new Title V vendors by December 1, 2026

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.

Higher Education Institutional Aid – Assistance Listing No. 84.031 Condition: Time and Effort documentation were not being documented and reviewed timely. Recommendation: We recommend that the Institution strengthen its internal controls to ensure that Time and Effort are documented, expenditures are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2024, we successfully implemented a new ERP system designed to automate the documentation of Time and Effort. This system streamlines the process by capturing and organizing data more efficiently, reducing manual effort and enhancing accuracy. As part of the implementation, we have established a process for regular reviews and adjustments of expenditures, ensuring ongoing compliance with regulatory requirements and maintaining the integrity of financial records. We are providing comprehensive training for relevant staff members, focusing on how to utilize the new system effectively. This training will ensure that documentation is completed in a timely, accurate, and consistent manner, minimizing the risk of errors and improving overall operational efficiency. Moving forward, we will continue to monitor the system's performance and provide ongoing support to ensure its success. Name(s) of the contact person(s) responsible for corrective action: Miliani Sinclair Planned completion date for corrective action plan: April 2025 igher Education Institutional Aid– Assistance Listing No. 84.031 Condition: Coppin State did not determine the suspension and debarment status on vendors with expenditures exceeding $25,000 during the fiscal year as required by federal regulations. Recommendation: The University should evaluate their current procedures and determine if they are adequate to prevent the finding from reoccurring. Policies and procedures should reiterate the three options for determining suspension and debarment status listed in 2 CFR 180.300. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Coppin State University has implemented a process as of May 2023 to ensure the SAMs.gov exclusion website is reviewed to determine the suspension and debarment status of its vendors, and documentation of that review is maintained. We will review SAM.Gov for expenditures exceeding $25,000 during the fiscal year as required by federal regulations. Name(s) of the contact person(s) responsible for corrective action: Thomas Dawson, AVP Procurement and Business Services Planned completion date for corrective action plan: The process to address the current finding will be implemented April 2025. Higher Education Institutional Aid– Assistance Listing No. 84.031 Condition: Morgan State University did not determine the suspension and debarment status on vendors with expenditures exceeding $25,000 during the fiscal year as required by federal regulations. Recommendation: The University should evaluate their current procedures and determine if they are adequate to prevent the finding from reoccurring. Policies and procedures should reiterate the three options for determining suspension and debarment status listed in 2 CFR 180.300. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding The Procurement department is testing that vendors are not listed as suspended or debarred, however no documentation was retained as proof. As a result, procedures will be expanded to specify the documentation process to demonstrate compliance with the Federal regulations. The procedure will emphasize the importance of a time stamp from the SAM.GOV verification. Name(s) of the contact person(s) responsible for corrective action: Nehemiah Yisrael Planned completion date for corrective action plan: April 11, 2025 igher Education Institutional Aid– Assistance Listing No. 84.031 Condition: University of Maryland Eastern Shore did not determine the suspension and debarment status on vendors with expenditures exceeding $25,000 during the fiscal year as required by federal regulations. Recommendation: The University should evaluate their current procedures and determine if they are adequate to prevent the finding from reoccurring. Policies and procedures should reiterate the three options for determining suspension and debarment status listed in 2 CFR 180.300. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: UMES procurement office has updated its policy and procedures to implement the recommendation from the audit finding. UMES procurement office will adhere and follow the steps laid out in 2 CFR 180.300 which states an entity may determine suspension and debarment status by:(a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.

Finding 2024-005 – Inadequate Procurement Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the InteriorFederal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Federal procurement standards require non-Federal entities to maintain records sufficient to detail the history of procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. Competitive procurement must follow the entity’s written procedures consistent with 2 CFR §§200.317-200.327, including:  Written procedures for procurement (§200.318(a)).  Full and open competition requirements (§200.319).  Methods of procurement (sealed bids, proposal requirements, and required documentation (§200.320).  Contract cost and price justification, (§200.324).  Suspension/debarment verification for covered transactions (§200.214; §200.213). Condition: During the audit period, the Entity did not retain sufficient procurement documentation for several contracts funded under the above Assistance Listings. Specifically, files lacked one or more of the following:  Evidence of the procurement method used.  Price or cost analysis.  Suspension/debarment checks for vendors where required.  Documentation of competition.  Conflict-of-interest attestations. Cause: Partnership for the Umpqua Rivers procurement procedures were not sufficiently detailed or consistently applied to federal purchases. No evidence of procedures or review for procurement or suspension / debarment was provided to auditors. Turnover and limited training on Uniform Guidance procurement standards contributed to the inconsistent file completeness. Effect or Potential Effect: Without complete procurement documentation, the Entity cannot demonstrate compliance with federal procurement requirements, increasing the risk of:  Noncompetitive awards or unreasonable prices.  Unallowable costs for the award requirements.  Potential disallowance or repayment of federal funds.  Findings in federal or pass-through monitoring and future audits. Questioned Cost: Yes, $902,496 related to expenditures that had no procurement support or detail. Context: During our audit, it was found that the Partnership for the Umpqua Rivers had experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to procurement, suspension or debarment procedures or processes. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Update Written Procurement Procedures o Incorporate Uniform Guidance thresholds and methods (§200.320), competition requirements (§200.319), and documentation expectations (history of procurement). o Embed steps for suspension / debarment checks and Appendix II Contract clauses.  Standardized Procurement Checklist o Pre-award checklist that verifies: method, competition evidence, cost/price analysis, conflict of interest attestations, SAM exclusion check, and required federal clauses. o Post -award checklist ensuring complete contract file (award memo, bid tab / evaluation, signed agreement, clause verification).  Cost/Price Analysis Guidance o Require documented price reasonableness for small purchases, formal cost or price analysis for larger or sole-source awards, per (§200.324).  Training & Accountability o Provide targeted training to procurement and program staff on 2 CFR §§200.317- 20.327 and Assistance Listing award conditions. o Implement supervisory pre-award review and periodic file audits. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

2024-006 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of our procurement testing in accordance with Uniform Guidance requirements, we requested that management provide the most recent suspension and debarment assessments for the vendors selected for review. Our analysis indicated that management did not perform these assessments by reviewing the federal government's suspended or debarred vendor list on SAM.gov. Rather, they relied on vendor certifications obtained through the Commonwealth of Pennsylvania, Department of Education, to determine vendor eligibility with respect to suspension or debarment from federally funded programs. Additionally, we observed that the current procurement policy for the CBS Food Program does not outline a formal procedure for evaluating vendors' suspension and debarment status as required by Uniform Guidance. Recommendation: We recommend that management establish and implement a formal process for evaluating vendors regarding suspension and debarment. This process should include regular reviews of the federal government's suspended or debarred list on SAM.gov to ensure that vendors are not suspended or debarred from participating in federal programs. Additionally, management should ensure that all procurement policies and procedures are updated to reflect this requirement. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions shall update its current procurement policy to include a suspension and debarment review of all vendors seeking to do business with the organization. Prior to February 13, 2026, Community Benefit Solutions shall conduct a comprehensive review of all current vendors to ensure compliance with these recommendations. Community Benefit Solutions will update procurement policy to include quarterly suspension and debarment review to be conducted by Quality Assurance Associate and signed off on by Warehouse and Purchasing Director. Planned completion date for corrective action plan: June 30, 2025

Federal Agency: U.S. Department of Agriculture Federal Program Name: Extension Services at 1890 Colleges and the Education Stabilization Fund Assistance Listing No.: 10.512; 84.425 Recommendation: We recommend the University implement and enforce procedures to verify vendor status through SAM.gov or other acceptable methods prior to award, retain documentation of the verification in procurement files, and train staff on suspension and debarment requirements under Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were implemented in FY26 to maintain documentation in Banner. The University has implemented additional procedures and buyers have been trained in checking SAM.gov for each federally funded Purchase Order. Name(s) of the contact person(s) responsible for corrective action: Eileen Butts, Director of Purchasing Planned completion date for corrective action plan: January 31, 2026

Capitalization Grants for Clean Water State Revolving Funds – Assistance Listing No. 66.468 COVID 19 ARPA Local Fiscal Recovery EXP – Assistance Listing No. 21.027 Recommendation: We recommend the Town design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred in accordance with 2 CFR section 200.213. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will implement a process to review vendors prior to entering into a contract to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman, Director of Finance Planned completion date for corrective action plan: December 2025 Any questions regarding this plan, please call Julie Chapman at (860) 848-6714.

Views of Responsible Officials (unaudited): The Organization agrees with the finding and recommendation. The Board of Directors of the Organization will develop policies and procedures to ensure they meet the Uniform Guidance Requirements.

Finding: Material weakness in internal control over documenting suspension and debarment reviews for vendors receiving federal funds Corrective action: PFI has adopted a policy to document the screening of all vendors receiving federal funds via the suspension and debarment list provided in SAM.gov. These procedures will be incorporated into PFI procurement policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director

Views of Responsible Officials and Planned Corrective Action: The Township has created a procedure to regularly check Sam.gov for suspension and debarment prior to issuing purchases orders or contracts and have it reviewed.

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, 2023 – June 30, 2024 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: December 31, 2025 If the third-party reviewer has questions regarding this plan, please call Simon Trowell, Chief Executive Officer at 215-563-0652

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Below $50k there will also be formal procedures with increasingly more oversight for purchases as they increase in cost. We will form and document a detailed procedure for issuing RFPs for PO amounts over $50k. We will review at least 3 proposals and once one is chosen, the vendor will be vetted before the proposal is accepted.

Management is not in agreement with this finding. The Organization has a policy in place to ensure that all contractors engaged with the Organization are being verified in advance of being engaged. This verification includes several security checks included verifying in required databases that they are not suspended or debarred. Senior management was not informed in time to produce the necessary documentation to the auditors. To ensure compliance in the future, management has revised its policy manual to include a formal checklist before signing any contracts for services.

In 2020, Intelligent Transportation Systems (ITS) was the sole bidder for the District’s camera project. The selected camera vendor was Hanwha Vision. In 2023, ITS was sold. At the time of the sale, ITS had only completed a portion of the project. On February 22, 2023, the District extended the GIS contract of Environmental Science Services (ES2) through February 17, 2024, and transferred the remaining scope of the camera project from ITS to ES2. The camera technology was integrated into the GIS environment for the District. The remaining cameras to be installed were purchased under the ES2 2023 contract at a lower price than in the ITS 2020 awarded low bid. In retrospect, the District should have rebid the project because the cameras were funded under the Port Security Grant Program (PSGP). The oversight was mainly caused by the transition of District executive personnel starting in 2023. Though this was an oversight, the camera technology integrated in the GIS environment increases the Port’s safety and security posture. The District now adheres to its newly adopted Procurement Policy to prevent recurrence. Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds to ensure full compliance with federal procurement standards, Louisiana Bid Law, Procurement Code, contract management protocols, and grant administration requirements: • The District is reviewing and updating its procurement policies to ensure alignment with federal procurement regulations, including those outlined in 2 CFR Part 200 (Uniform Guidance). All PSGP-funded procurements will be subject to competitive bidding procedures, proper documentation, and approval protocols to ensure transparency and compliance. • The District has reinforced its procurement procedures to ensure that all purchases exceeding $60,000 are formally advertised and awarded in accordance with Louisiana Revised Statute 38:2212. For purchases between $30,000 and $60,000, staff are required to obtain, document, and retain at least three competitive quotes in the procurement file. No significant purchases will be made without prior approval from the governing authority. • Formal procedures have been implemented to ensure that all PSGP-related contracts are properly executed, monitored, and supported by complete documentation. These procedures will includes verification of scope, deliverables, and performance timelines prior to payment authorization along with any solicitations, bids or quotes, evaluations, approvals, and any supporting documentation required by law and internal policy.• The District has designated a marine inspector to oversee PSGP grant activities, including expenditure review, documentation standards, and reporting requirements. All disbursements will be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance. • Management is actively consulting with FEMA to assess the allowability of identified questioned costs. The District will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in procurement, contract management, and grant administration. These sessions will cover federal compliance requirements, internal control

We have changed the process so all contracts are collected at the SAU central office to ensure completeness.

Corrective Action Plan (Unaudited): To address this finding and prevent future recurrence, the City will implement the following corrective actions: 1) Updated grant management policies and procedures: The new grant management policy and procedures will explicitly cover informal procurements funded with federal dollars, highlighting the need for compliance with the Uniform Guidance and requiring suspension and debarment checks regardless of contract type. 2) Procurement controls: Procurement will continue conducting SAM.gov checks for all federally-funded vendors, including any payments that hit grant funds within the financial system, and save documentation in the contract files. 3) Training: Annual training will emphasize the uniform guidance, specifically suspension and debarment rules, with added focus on informal procurements and direct payments without a contract. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026

Corrective Action Plan (Unaudited): To address this finding and prevent future recurrence, the City will implement the following corrective actions: 1) Updated grant management policies and procedures: The new grant management policy and procedures will explicitly cover informal procurements funded with federal dollars, highlighting the need for compliance with the Uniform Guidance and requiring suspension and debarment checks regardless of contract type. 2) Procurement controls: Procurement will continue conducting SAM.gov checks for all federally-funded vendors, including any payments that hit grant funds within the financial system, and save documentation in the contract files. 3) Training: Annual training will emphasize the uniform guidance, specifically suspension and debarment rules, with added focus on informal procurements and direct payments without a contract. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026