Corrective Action Plans

2026-001 Suspension and Debarment Corrective action planned: To ensure full compliance with federal documentation standards moving forward: 1. Formalized Onboarding Control: In May 2026, the Organization updated its standard New Vendor Form to include a mandatory verification checkbox and documented sign-off confirming SAM.gov exclusion checks are completed prior to vendor setup or contract execution. 2. Existing Vendor Audit: Management is currently conducting a comprehensive review to document and retain SAM.gov exclusion verifications for all active vendors. Anticipated completion date: May 2026 Contact person responsible for corrective action: Scott Matlock

Inadequate Procurement Documentation - HPC - MDT - The Montana Department of Transportation has developed a tracking spreadsheet for independent cost estimates and will continue to provide reminders and training through 2026. The department will update its procedures to ensure documentation for suspension and debarment checks and cost estimates is retained in consultant files. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Dustin Rouse, Chief Engineer, Montana Department of Transportation Target Implementation Date - 12/31/2026

City Response and Corrective Action Plan: Management agrees with the recommendation. Moving forward the City will check vendors in SAM.gov before awarding contracts and will recheck them at least once a year for multi year agreements. Each check will be recorded in a central log, and supporting documentation will be kept in our contract and grant files. When needed, the City will collect a vendor certification at the time of award and review compliance annually. The City expects full implementation of these procedures within 60 days, with ongoing monitoring after that.

Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with vendors, contractors, or subrecipients. Criteria Organizations that receive federal funding are generally required, under 2 CFR § 200.318–200.327 (Uniform Guidance), to: • Maintain written procurement procedures that conform to applicable federal, state, and local laws; • Ensure procurement transactions are conducted in a manner providing full and open competition; • Verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded from participating in federal programs, per 2 CFR § 200.214 and 2 CFR Part 180. Cause The Institute has not formalized its procurement practices in a written policy and staff is not currently required to check suspension and debarment status as part of the vendor selection or contracting process. Effect Without a written procurement policy, the Institute lacks a consistent, auditable standard for procurement decisions, increasing the risk of non-compliance, favoritism, or inconsistent practices across departments. The absence of suspension and debarment checks creates risk that the Institute could enter into agreements with parties who are legally excluded from receiving federal funds, potentially resulting in disallowed costs, reputational harm, or loss of funding. Recommendation The Institute should develop and formally adopt a written procurement policy that addresses methods of procurement, competition requirements, documentation standards, and conflict-of-interest provisions consistent with 2 CFR § 200.318–200.327. The Institute should also implement a documented procedure requiring suspension and debarment verification (via SAM.gov or equivalent) for all vendors, contractors, and subrecipients prior to contract execution, and retain evidence of this check in procurement files. Management Response Management agrees with the finding and recommendation. The Institute is formalizing its procurement practices in a written procurement policy consistent with applicable Uniform Guidance requirements. The policy addresses procurement methods, competition, documentation, conflicts of interest, and suspension and debarment requirements for procurements in accordance with federal regulations. Action Taken The Institute contracted with Visual Compliance to assist with verifying vendors against all available U.S. debarred and suspended lists before entering into covered contracts or agreements with vendors, contractors, or subrecipients. The Institute has developed and approved a Suspension and Debarment policy and staff are required to check suspension and debarment status as part of the vendor selection or contracting process. The Institute is developing a written procurement policy. Evidence of the verification will be retained with the applicable procurement or agreement documentation.

Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.

CITY OF GOSHEN CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLRF) – Suspension and Debarment Contact Person Responsible for Corrective Action: Goshen Clerk-Treasurer Richard R. Aguirre Contact Phone Number and Email address: 574-533-8623; richardaguirre@goshencity.com Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future expenditures involving federal programs, and prior to entering into covered transactions, the City of Goshen will verify that all contractors and subrecipients are not suspended or debarred or otherwise excluded by using one or more of the following procedures: (a) incorporating the required suspension and debarment language into fully executed agreements, (b) obtaining written or emailed certification from vendors confirming they are neither suspended nor debarred, (c) verifying vendor status through the applicable federal suspension and debarment database (Excluded Parties List System, EPLS). The City has included suspension and debarment clauses in many contracts involving the use of federal and state monies since 2023. However, due to an internal misunderstanding within another City Department, the agreement at issue was not identified as being subject to the federal suspension and debarment requirement. That is because, in April 2024, the City awarded a contract to a local contractor for the Steury Avenue and Lincoln Avenue Reconstruction and Drainage Improvement project and the Goshen Common Council did not approve using $5,086,932.81 in American Rescue Plan funds (SLRF) for that project until Dec. 16, 2024. So, there was no verification before the expenditure of $1,875,887 of SLRF funds for the contractor in 2025. As of the date of this corrective action plan, the Clerk-Treasurer’s Office has verified that contractors and vendors paid with federal funds in 2025 and 2026 (including the contractor identified in Finding 2025-002) are not suspended or debarred or otherwise excluded. Going forward, the Clerk-Treasurer’s Office and the Grant Coordinator will coordinate more closely with all City departments to improve awareness of the suspension and debarment compliance requirements associated with federal awards. This enhanced communication and oversight is intended to prevent similar instances of noncompliance in the future. Anticipated Completion Date: City officials and key staff members have been reminded of these verification procedures through verbal communication, email, or both. By Dec. 31, 2026, City staff will receive additional guidance from Clerk- Treasurer’s staff on identifying when suspension and debarment requirements apply to vendor contracts and on following the City's established verification procedures before contract approval and execution. – Completed and resubmitted to the State Board of Accounts, August 10, 2026

Emergency Solutions Grant – Assistance Listing No. 14.231 Recommendation: We recommend that management implement formal procurement policies requiring periodic reassessment of vendors used in federally funded programs, particularly when new grant awards are received or grant periods change. This should include evaluating whether the original procurement method remains appropriate, performing updated cost or price analyses as necessary, and conducting and documenting periodic suspension and debarment checks (e.g., SAM verification). Additionally, management should establish oversight controls to ensure procurement compliance and vendor eligibility are maintained throughout the lifecycle of vendor relationships in accordance with 2 CFR §200.318–200.320 and §200.214. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Avivo is in the process of updating its procurement policy and processes to include annual reviews of ongoing vendor contracts that will assess the appropriateness of the original procurement conditions and determine if updates or new analyses are required. Reviews will be signed off by the staff with contracting authority at the time of review; and if warranted, the appropriate staff will undertake new cost analyses, complete the documentation, and save in a shared repository that relevant departments will have access to. Program leadership is working with the appropriate administrative departments to develop the necessary processes for periodic review and the collection/storage of documentation around the periodic review process. The Accounting department has added a system-wide debarment check of all active vendors in the 3rd quarter of each year and will add any new vendors to this schedule regardless of when they were originally added to the vendor payment system. This ensures that all vendors are re-checked for debarment and suspension at minimum of one time annually. Name(s) of the contact person(s) responsible for corrective action: Kelly Matter Planned completion date for corrective action plan: 12/31/2026

Finding Reference Number: 2025-003 – Internal Control over Compliance in Relation to Procurement Suspension and Debarment Description of Finding: This is a new finding. Upon review of the town’s Bid Ordinance and Charter, a policy could not be found that determines whether a vendor for goods and services was either suspended or debarred from receiving or participating in federal awards, which is required as part of the 2025 Uniform Guidance related to Federal Programs. Additionally, it could not be determined whether any suspension or debarment review had been made and documented. Statement of Concurrence or Nonconcurrence: Concur. Corrective Action: The town will update the Town Bid Ordinance to include the policy that mandates that before any contract or purchase order is awarded using federal funds, staff must verify the vendor’s eligibility status via the federal System for Award Management (SAM.gov). The Town will also update its Policy and Procedures manual to require a printed or digital SAM.gov search certificate to be attached to the procurement file as auditable evidence of the verification. Projected Completion Date: December 31, 2026

Finding 2025-002 Procurement, Suspension and Debarment Material Weakness in Internal Control Over Compliance and Instance of Material Noncompliance Assistance Listing 21.029 Wabash currently maintains the process of procurement standards and internal controls. While we previously managed contractor selections through established internal practices, we recognize the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash implemented a formal Procurement Policy and Procedure June 30, 2026. This document mandates: • Standardized Selection Criteria: Clear guidelines for the evaluation and selection of contractors to ensure transparency and competition. • Debarment Verification: A required protocol for verifying and documenting that contractors are not excluded or debarred via the System for Award Management (SAM). • Oversight: The Network Operations will be responsible for the implementation and ongoing monitoring of these controls to ensure full regulatory compliance. These measures will ensure that all future procurement activities meet federal requirements and organizational standards for financial integrity. Contact person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer

Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement - Suspension and Debarment Type: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context: During our audit, we noted a deficiency related to suspension and debarment verification and documentation. Specifically, for the procurement transactions tested, Worcester County, Maryland did not document verification that the vendor was not suspended or debarred prior to contract execution. In addition, the County does not have a formally documented suspension and debarment policy. While management indicated that suspension and debarment checks may be performed in practice, the absence of written policies and procedures resulted in inconsistent application and documentation of this required compliance procedure. Uniform Guidance requires non-federal entities to ensure that vendors and contractors receiving federal funds are not suspended or debarred from participating in federally funded programs. Effective compliance with this requirement is supported by documented policies and procedures that require verification (e.g., review of the System for Award Management (SAM.gov)) prior to entering into contracts. Recommendation: The County should develop and formally document a suspension and debarment policy that requires verification and documentation of vendor eligibility (e.g., SAM.gov review) for all contracts supported by Federal awards prior to execution of the contract. Management should also consider implementing standardized checklists or review controls to promote consistent compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Worcester County plans to update the County purchasing, financial and grant policies ensure debarment and suspension compliance by implementing procedures aligned with the U.S. Office of Management and Budget Uniform Guidance (primarily 2 CFR Part 200) and the governmentwide debarment rules in 2 CFR Part 180, as adopted by the awarding agency. The corrective action includes implementing a written procurement policy which states that the county will not contract with or issue subawards to parties that are suspended or debarred when federal funds are involved. The Grant/Budget Office will maintain open communication with Procurement regarding federally funded grant projects that will be advertised for bid. After bids are received and before the evaluation committee reviews or recommends an award, the Grant/Budget Office will search the System for Award Management (SAM.gov) exclusion database for each vendor that submitted a bid. A PDF or screenshot of the SAM search for each vendor will be retained in a grant and procurement file. All other federal grants under procurement threshold will need county departments to reach out to the Grant/Budget office before choosing vendors. Departments will need to list their potential vendors for the federal grant and email to the Grant/Budget office for debarment verification before moving forward with expending federal grant funding. A PDF or screenshot of the SAM search for each vendor will be sent to the department and a copy kept by Grants/Budget office as well. Name(s) of the contact person(s) responsible for corrective action: Kimberly Reynolds, Budget Officer kreynolds@worcestermd.gov Planned completion date for corrective action plan: Fiscal Year 2027

BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026

We acknowledge that internal control should be strengthened by reviewing the current BGCPR Fiscal Policy, and effective September 30, 2026, all vendors must be verified who are not excluded or disqualified at System for Award Management (SAM.gov). This verification will be incorporated into the Workflow system and maintained as part of the vendor approval process. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.

Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of the Treasury Award Number and Year: 2021 Compliance Requirement: Procurement and Suspension and Debarment Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The program managers lacked a complete understanding of federal grant requirements and overlooked this procedure. To resolve the matter, the City Manager and department leaders convened and suggested that staff receive proper training. They will continue to review the training schedule, factoring in staff availability, venue options, and budget limits. All current non-Federal entities have been verified. Name of Responsible Person: City of Merced’s Leadership and Grant Program Managers Projected Implementation Date: June 30, 2027

U.S. Department of Health and Human Services American Society for Microbiology (the Society) respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 1 – December 31, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Services 2025-001 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security – Assistance Listing No. 93.318 Recommendation: We recommend the Society enhance controls to ensure adequate documentation is retained to support the procedures are performed timely with respect to vendor evaluation for suspension or debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has updated the internal procurement process documentation to include specific preparer and reviewer sign offs required to demonstrate the date that suspension and debarment checks were completed. Name(s) of the contact person(s) responsible for corrective action: Sharon Oluga Planned completion date for corrective action plan: 07/31/2026 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Oluga at 202-942-9284.

2025-005 – Lack of Documentation for SAM.gov Exclusion Checks Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Organization did not retain documentation to support that the exclusion checks were performed for vendors. As a result, there is no evidence that the Organization verified whether these parties were suspended or debarred prior to entering covered transactions. Auditor Recommendation. We recommend that the Organization retain evidence that SAM.gov exclusion checks are being completed for vendors to document that vendors are not suspended or debarred prior to entering covered transactions. Corrective Action. The Organization will begin retaining documentation for its SAM.gov exclusion checks that it completes for vendors to verify whether these parties were suspended or debarred prior to entering covered transactions. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

Onvida Health Management will revise/update existing procurement and/or grant policies to incorporate all Uniform Guidance requirements related to micro-purchases, small purchases, competitive proposals, and documentation of cost or price analysis. Procedures for verifying suspension and debarment status will also be formally addressed in these policies. Responsible Official: Dana Alexander, Controller Completion Date: Any outstanding items not already completed that are listed in the corrective action plan, will be completed by an estimation date of October 1, 2026.

2025-011 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing Number 21.027 Recommendation: We recommend that the City strengthen its written policies, procedures, and internal controls to require suspension and debarment verifications before entering into Federally funded contracts and that verification be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:  Soundthinking LLC – Police Department  The Manchester Police Department will follow its SOP - Sam.gov Verification for Subrecipients and Vendors Standard Operation Procedure (enclosed) confirming Entity Registration Status (Active / Inactive), Exclusion Status (Suspended, Debarred, Ineligible), and the Expiration Date of all vendors. This process will be completed by the Grant Coordinator in coordination with the Project Manager (if applicable). All documentation will be maintained within the official electronic grant file complying with federal retention dates. Name(s) of the contact person(s) responsible for corrective action:  Whitney Dade, Grant Coordinator, MPD Action taken in response to finding:  Environmental Partners – DPW-Highway: 712522 – DPW agrees with findings and will create a prequalification SOP to complete and record SAM.gov queries on suspensions and debarment verifications prior to entering into contracts. This will be completed within 90 days of today.  Denisco Electric - DPW-Highway: 71222 – DPW agrees with findings and will create a prequalification SOP to complete and record SAM.gov queries on suspensions and debarment verifications prior to entering into contracts. This will be completed within 90 days of today.  GMI Asphalt LLC - DPW-Highway: 712522 – DPW agrees with findings and will create a prequalification SOP to complete and record SAM.gov queries on suspensions and debarment verifications prior to entering into contracts. This will be completed within 90 days of today.  All future prequalification packages will include a requirement for Manchester DPW to complete the SAM.gov verification in addition to the other assertions already made by the contractor/engineering firm.  In addition an SOP will be created to detail how the SAM.gov verification will be conducted prior to contract and where this info for each entity will be archived for a minimum of 3 years following the end of the program. Name(s) of the contact person(s) responsible for corrective action:  Caleb Dobbins – Chief Highway Engineer, DPW Planned completion date for corrective action plan:  9/30/2026 Action taken in response to finding:  39 Beech Street LLC – Mayor’s Office / Fire Department - agrees with the finding and will create a prequalification SOP to complete, record SAM.gov queries on suspensions and debarment verifications as part of a checklist prior to entering into contracts. Name(s) of the contact person(s) responsible for corrective action:  Mayors office - Kathleen Pelissier, Grants Coordinator  Fire Department – Melissa Paulhamus, Administrative Services Manager Planned completion date for corrective action plan:  9/30/2026

Finding 2025-004 Federal Agency Name: United States Department of Health and Human Services Program Name: Congressional Directives FFAL #93.493 Finding Summary: The Hospital does not have an internal control policy in place to ensure covered transactions are with vendors that are not suspended or debarred, and no evidence was retained regarding ensuring the vendor was not suspended or debarred. Corrective Action Plan: For Finding 2025-004, the Hospital has implemented corrective actions to address the lack of internal controls related to suspended and debarred vendor verification. The Hospital revised its Capital Request Form to require documented verification that vendors involved in federally funded procurements are not suspended or debarred prior to contract award or purchase. Additionally, the Federal Procurement Policy and Procedure was updated to establish formal internal controls for screening vendors against applicable federal exclusion lists and retaining evidence of the verification process. Effective immediately, no procurement involving federal funds will be approved until suspended and debarred status verification has been completed and documented. Management will provide education to all managers on August 5, 2026, regarding the revised requirements and documentation standards. Hospital leadership will conduct ongoing monitoring and review of procurement files to ensure compliance with federal regulations and to prevent recurrence of this finding. Responsible Individuals: Wesley Babers, Chief Executive Officer and Ashley Jaramillo, Chief Financial Officer Anticipated Completion Date: August 2026

FINDING 2025-001 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Lorrie K. Pontius Contact Phone Number and Email Address: 260-925-6450 x1101 lkpontius@ci.auburn.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Corrective Action Plan will require verification through the Excluded Parties List System (EPLS) in SAM.gov before any award, contract execution, renewal, or contract modification is approved. Verification will be printed and/or saved as a PDF copy of the SAM.gov search results showing the date of the verification and the search outcome. Then verification documentation will be sent to a secondary reviewer electronically and maintained in the contract file according to records retention policy. Anticipated Completion Date: As a corrective measure, verification through the EPLS in the System for Award Management (SAM.gov) will be conducted immediately as of the completion date of this CAP, June 3, 2026 and prior to any award, contract execution, renewal, or modification.

Suspension and Debarment California Department of Public Health The California Department of Public Health (CDPH) agrees with this finding. CDPH has implemented interim procedures to verify vendor suspension and debarment status prior to the execution of federally funded procurements, including agreements funded through emergency programs. CDPH is in the process of finalizing department-wide procedures and updating procurement checklists to ensure compliance with federal requirements. Until the formal procedures are published, staff will continue applying the interim procedures to ensure all required verifications are completed and appropriately documented in procurement files. Estimated Implementation Date: July 2026 Contact: - Louise Karsten, Emergency Funding Coordination Branch Manager, Center for Preparedness and Response

Subrecipient Monitoring California Department of Aging Certification: The Department will incorporate a standard suspension and debarment certification clause into all subrecipient agreement templates, requiring each subrecipient to certify it is not suspended, debarred, proposed for debarment, or otherwise excluded from participation in federally funded transactions, consistent with 2 CFR §200.214 and 2 CFR Part 180, Subpart C. SAM.gov verification: Prior to executing any covered transaction, program staff will perform and document a search of the subrecipient in the SAM Exclusions database (SAM.gov). A screenshot or printed confirmation of the search results (including the date performed and the staff member who performed it) will be retained in the subrecipient's contract file. Checklist and Desk Procedures: The Department will update the checklist to include both a UEI/registration verification step and a separate Exclusions/Debarment verification step. Desk procedures will be updated to ensure staff follow the checklist and verify both the UEI and Exclusions status on SAM.gov. Retroactive review: For the eight subrecipient agreements identified in this finding, the Department will perform and document SAM.gov Exclusions to confirm suspension/debarment status, in addition to UEI verification, and retain the results in each contract file. Training: Staff responsible for subrecipient monitoring will receive training on the distinction between UEI/SAM registration checks and suspension/debarment exclusion checks, and on where to document each in the file. Estimated Implementation Date: September 2026 Contact: - Han Pham, Section Chief Business Management

The Partnership will develop and implement comprehensive written subrecipient monitoring and procurement policies aligned with Uniform Guidance. Procedures will include verification of suspension and debarment status (e.g., SAM.gov), incorporation of required compliance terms in subaward agreements, tracking of subrecipient funding by program, implementation of a risk-based monitoring framework, and documentation of monitoring activities including financial and programmatic reviews. Staff will be trained on these updated procedures, and compliance reviews will be centralized within the finance and administrative function.

The City’s Corrective Action Plan to address the condition is to put controls in place to ensure all vendor contracts are verified for clearance from the suspended and debarred SAM.gov system and that information be maintained in the City’s records.

FINDINGS 2025-002 Contact person responsible for Corrective Action: Christi McElhaney, City Clerk Treasurer Contact phone number: 260-356-1400 x2016 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City continues to develop and implement controls that will ensure that all vendors used for Federal Grants will be checked for suspended and debarment within the SAM.gov website and/or include in the contract with the vendor. Anticipated completion date: July 31, 2026