Corrective Action Plans

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

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.

Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency and accountability in our operations. Managements Response to Audit Finding on inadequate recording of procurement history or justification: 1. Review and Update Procurement Policies:  We will conduct a thorough review of our current procurement policies and procedures to identify any gaps or areas requiring improvement.  Updates will be made to ensure that our procurement policies align with federal regulations, including those related to suspension and debarment. 2. Training for Staff:  We will provide comprehensive training for all staff involved in the procurement process to ensure they understand the updated policies and the importance of maintaining proper records.  Training will include guidance on documentation requirements, vendor selection criteria, and compliance with federal regulations. 3. Implementation of Record-Keeping System:  We will implement a centralized, secure, and user-friendly record-keeping system to document all procurement activities.  This system will include templates and checklists to guide staff in capturing all necessary information, including vendor selection, bid evaluations, contract awards, and verification of suspension and debarment status. 4. Regular Monitoring and Audits:  We will establish a schedule for regular internal audits of the procurement process to ensure ongoing compliance and to identify any potential issues promptly.  Findings from these audits will be reviewed by senior management, and corrective actions will be taken as needed. 5. Vendor Verification:  We will enhance our procedures for verifying the suspension and debarment status of potential vendors before awarding contracts.  This verification process will be documented and retained as part of the procurement records. Conclusion: FASEB is committed to addressing the findings related to procurement and suspension and debarment. We believe that the steps outlined in our corrective action plan will ensure compliance with Federal regulations and enhance the integrity and transparency of our procurement process. We appreciate the opportunity to improve our practices and will provide updates on our progress as requested.

The National Conference of State Historic Preservation Officers respectfully submit the following corrective action plan for the year ended December 31, 2024 Name and address of independent public accounting firm: CBIZ 1899 L Street, NW, Suite 850 Washington, DC 20036 Audit Period: January 01, 2024 to December 31, 2024 The findings from the Schedule of Finding for the year ending December 31,2024, are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding No. 2024-001 Revenue Recognition – Significant Deficiency in Internal Control over Financial Reporting: The finding was that NCSHPO provided a trial balance and SEFA that omitted indirect cost rates on accrued direct expenditures through December 31, 2024. Contacts for Corrective Action: Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465 Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465 The NCSHPO only recognized the direct costs as revenue for the period ending 12/31/24 not considering that the indirect cost rate should be accrued as revenue also thus causing the SEFA to not balance with the Trial Balance at the end of the year. NCSHPO agreed with CBIZ that the indirect costs should be recognized. The NCSHPO will begin a new internal control procedure to recognize the indirect costs as revenue to include on the SEFA schedule monthly beginning July 1, 2025. The SEFA and the Trial Balance will be reconciled for each job report. When Accounts Receivable (1120-000-0000), Revenue (4700-104-XXXX) and Administration fee/Indirect costs (4420-000-0000) are reconciled, then the SEFA, the Trial balance and the journal entry transaction(s) to recognize revenue will be given to the Executive Director to review and approve to be entered into the General Ledger. Implementation date: 07-01-2025 Finding No. 2024-002 Procurement – Significant Deficiency in Internal Control Over Compliance RE: Federal Award Identification Numbers P17AC00528 and P22AM01146 The finding was that NCSHPO failed to perform the required search of vendors per Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Section 200.213. NCSHPO agreed with CBIZ that we did not do a search for suspension and debarment in SAM for any of the vendors and that it was not included in our Procurement Policy. Contacts for Corrective Action: Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465 Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465 The NCSHPO updated the Procurement Policy to include a section for Suspension and Debarment. NCSHPO then used SAM to obtain the proper documentation to include in each respective vendor’s file. The NCSHPO will implement the new procedure to do a search in SAM.gov for every vendor it selects to do business with under the Cooperative Agreement and continue to do the search annually. Below is the new policy that is included in NCSHPO’s Procurement Section: Suspension and Debarment: NCSHPO verifies that the vendor or subrecipient with whom NCSHPO intends to do business is not excluded or disqualified in accordance with 2 C.F.R. Part 200, Appendix II (1) and 2 C.F.R. §§ 180.220 and 180.300. Before final selection, the Business Manager or the Special Projects Manager will perform a search on the General Services Administration Excluded Parties List System (EPLS) (http://www.sam.gov). Results of the screenings should be printed and placed in the procurement file. Suspension and debarment checks will be updated annually and will remain documented in the procurement file in line with NCSHPO’s document retention policy. The ED ensures this is completed during inspection and approval of procurement. Implementation date: 04/30/2025

Views of Responsible Officials: HIAS management accepts this comment and is finalizing a new comprehensive policy on the vetting of contractors and other third parties.

The American Immunization Registry Association (AIRA) respectfully submits the following corrective action plan for the year ending September 30, 2024. Independent public accounting firm: HAN GROUP, LLC, Washington, DC Audit period: Year ending September 30, 2024 The finding from the year ending September 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2024-001 – Procurement, Suspension and Debarment. Audit Recommendation – Strengthen internal controls over procurement documentation by: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. Management Response – AIRA acknowledges the finding and will implement the following: 1. Procurement Checklist: A standardized procurement checklist will be developed and required for all federally funded procurements. This checklist will help ensure consistent documentation practices and that all necessary procurement steps and compliance elements are completed and retained. Documentation of the completed checklist will be retained in the procurement file. 2. Vendor Eligibility Verification: A formal review process will be established to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. Documentation of the eligibility check will be retained in the procurement file. 3. Staff Training: Targeted training sessions will be conducted on a recurring basis for all staff involved in the procurement process. These trainings will reinforce federal compliance requirements, including proper documentation practices and suspension/debarment verification. Training completion will be tracked and documented. Implementation Timeline – As of March 18, 2025, AIRA has implemented a verification of vendor eligibility process using SAM.gov. The procurement checklist will be developed and implemented by April 30, 2025, and regular trainings will commence by May 31, 2025. We are committed to ensuring full compliance with federal procurement requirements. Please contact the Business and Operations Director at 202-552-0208 with any questions.

Planned Corrective Action: It is the policy of the Seattle Indian Health Board to retain documentation that a new vendor is not debarred from doing business with the federal government. In certain circumstances, due to the age of the vendor or other reasons, the documentation was not maintained. Management has engaged the accounts payable team to perform a review of all vendors accounts to assure all required documentation is on file and to continue this review on an annual basis. Name of Responsible Party: Brian Jonas., Controller Anticipated Completion Date: September 30, 2025

Views of Responsible Officials: Working diligently with NIH team to put policies and procedures in place to conduct the proper screenings for vendors, suppliers and consultants.

Based on the nature of this finding, it has been determined that this finding has been isolated to the Harris County Purchasing Department who has the oversight of issuing all purchase orders pertaining to Countywide grants. The Harris County Purchasing Department along with each sub-awarded County department will work to ensure the suspension and debarment requirements will be met as indicated in the Harris County Federal Procurement Policy Manual, adopted by Commissioners Court on March 8, 2022. The County Purchasing Agent shall work to implement the following controls to ensure all federal procurement requirements will be followed: • Obtain funding information from using departments to determine whether the procurement falls under federal funds. • If the procurement does fall under federal funds, a SAM.gov verification requirement will occur prior to processing the request for Commissioners court approval and/or approving a purchase order. • Require the purchase order requestor and/or purchasing agent to capture the date and website information to confirm the SAM.gov verification was performed in a timely manner. The County Purchasing Agent recognizes the importance of having debarment and suspension verifications included in the procurement file. The Harris County Purchasing Department is in the process of revising our internal procedure for Suspension and Debarments (SAMS) for contracts both below and above the $50,000 threshold. The existing internal procedure, last updated in 2018, is no longer adequate. By revising this procedure, we will ensure compliance with federal, state, and local procurement regulations.

Finding No. 2024-002: Procurement – Material Weakness in Internal Control Over Compliance Contact for Corrective Action: Jayson Tischler, Chief Operating Officer The Organization needed to sole source its architectural firm because it was mission-critical on a compressed timeline with the New Markets Tax Credit financing process. The Organization’s construction owner’s representative firm, D3 Development, LLC, undertook a market review that confirmed fair and reasonable pricing and service for the selected architectural services. The Organization then subsequently received a federal grant after the construction project began, which allowed the Organization to reimburse for architectural expenses. The Organization was able to reimburse through budget approval from HUD for those retroactive expenses, where competitive bidding had not been a requirement for the organization for any existing federal grants or awards. To ensure future compliance with federal procurement requirements, the Organization will revise its procurement policy to require a competitive bidding process, and proper documentation and record keeping of such, for all vendors eligible for reimbursement under federal programs. Additionally, the Organization will include suspension and debarment confirmation through the System for Award Management (SAM) in its procurement policy for all contractors. The Organization believes that these steps outlined above address this corrective action. Expected Completion Date: April 2025