Corrective Action Plans

2026-002 Suspension and Debarment Corrective action planned: CSV verifies each vendor’s exclusion status in SAM.gov before entering into any contract, purchase order, or agreement of $25,000 or more paid with federal funds. Each verification is documented, and active vendors are re-verified annually. Initial verification records for new vendors are retained in the Vendor Record within CSV’s general ledger system. Annual vendor verification records are documented and maintained in CSV’s electronic files. These procedures apply to all federal awards received by the organization Anticipated completion date: Completed in June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

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

Finding 2025-001 Federal Program: Coronavirus State and Local Fiscal Recovery Funds COVID-19 (ALN 21.027) Contact Person Responsible for Corrective Action: Financial Services Director Corrective Action Planned: The City will revise procurement procedures to require retention of documentation supporting SAM.gov suspension and debarment verification for all covered transactions. A standardized procurement checklist will be implemented and reviewed by supervisory personnel prior to contract execution. Procurement staff will receive training on federal procurement requirements and documentation retention procedures. Anticipated Completion Date: September 30, 2027 Management Response: The City concurs with the finding and will implement the corrective actions described above.

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services in excess of $15,000, in which Auditor participated and was subsequently provided with the procurement operations and results, complete with Auditor’s own competitors. Vendor/Partner Contracts: The specific vendors and subcontractors were evaluated, vetted, and formally approved by the U.S. Department of Transportation (USDOT) during the competitive application and award phase of the Thriving Communities program. The Regulation: Under 2 CFR 200 (specifically regarding procurement by non-federal entities), if a federal awarding agency explicitly approves specific subrecipients or contractors as part of the federal award, it generally waives the requirement for subsequent competitive procurement for those designated roles. See USDOT-approved budget line items showing the named vendors (see USDOT Approved Budget” attached). All records are on file with the USDOT. Subrecipient/Contractor Monitoring: COMTO provided clear, signed agreements with these preapproved vendors that pass down all federal compliance requirements (e.g., Title VI, civil rights compliance, reporting metrics) required by the Thriving Communities program. Auditor has not clarified exactly which federal or local regulation they believe requires a rebid of USDOT-approved project partners (see executed contracts attached). COMTO does not run a competitive bidding or procurement process to select a subrecipient. They were selected as collaborative partners/sub-awardees and their status as subrecipients was explicitly authorized by the USDOT when they approved our grant award. All records are on file with the USDOT.

Finding 2025-05 Procurement and Suspension and Debarment: Retention of Debarment Checks – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Planned Corrective Action Plan: APU will revise its federal procurement procedures to require verification of vendor suspension and debarment status before entering into applicable covered transactions. Evidence of verification, including SAM.gov documentation, vendor certification, or applicable contractual language, will be retained in the procurement file.; Anticipated Completion Date: July 1, 2027

Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: Testing of the federal program identified the following: a. The Organization’s formally documented procurement policy is missing one required element as it relates to domestic preferences (2 CFR 200.322). b. Two lease agreements were entered into where the Organization did not follow the procurement process as detailed in the procurement policy. The lease agreements with the vendors were also missing a required contract provision in accordance with Uniform Guidance and there was no review performed by the Organization to ensure the vendors were not suspended or debarred as the lease agreements with the vendors were over $25,000. Corrective Action Plan: Management will implement a checklist to ensure the Procurement Policy is being followed. In addition, management will review the procurement policy elements and update our procurement policy to ensure it incorporates all required elements. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director and Christina Thoelke, Business Manager Anticipated Completion Date: September 2026

Corrective Action: Management agrees with the finding. Management intends to develop and implement written policies and procedures, provide staff training, and establish a vendor verification process designed to ensure compliance with Uniform Guidance procurement and suspension and debarment requirements. Anticipated Completion Date: December 2026 Personnel Responsible for Corrective Action Plan: Cyndi Hanson, Chief Financial Officer

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. One contract tested did not contain all applicable Uniform Guidance contract provisions. In one instance involving contracts exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Corrective Action Plan: KCEC will update its procurement procedures to incorporate applicable Uniform Guidance requirements. Debarment checks will be completed and documented for all vendors prior to contract execution while also ensuring that contracts contain attestation that the vendor affirms they are not disbarred. Contracts will be reviewed to ensure all required federal provisions are included. KCEC's Grant and Compliance accountant will strengthen its contract review process to ensure federal guidelines and language is present and included in contract verbiage by actively participating in contract negotiations between the vendor and KCEC. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

Identification of the Federal Program: Grantor: United States Department of Health and Human Services, Health Resources and Services Administration Program Name: Congressional Directives Assistance Listing No.: 93.493 Responsible officials: Joe Wilson, Koji Mabuchi Vice President Supply Chain, CPO, Sr. Director Corporate Compliance Phone: (914) 349-8701, (718) 920-6351 Email: joawilson@montefiore.org, kmabuchi@montefiore.org Projected completion date: March 30, 2027 Condition Title 2, Subtitle A, Chapter II, Part 200, Subpart D 200.320 – Procurement methods – requires entities to maintain documented procurement procedures and appropriate supporting documentation for procurement methods, including noncompetitive procurements. Purchases below the simple acquisition threshold, but above the micro-purchase threshold require price and rate quotations to be obtained from an adequate number of qualified sources. The Health System did not retain documentation demonstrating either (1) competitive bidding was performed or (2) the justification and circumstances supporting the use of a noncompetitive procurement method for equipment, installation and broadband services purchased under the grant. The procurement transactions reviewed exceeded the micro-purchase threshold; however, no supporting competitive procurement or sole-source documentation was available for audit inspection. In accordance with Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 - Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. The Health System has an established process to monitor vendor suspension and debarment requirements. Management’s process includes suspension and debarment evaluations on all new vendors prior to entering into any business relationship. The Health System utilized a third party to perform monthly suspension and debarment reviews; however, vendors associated with the program were not included in the listings provided to the third party for review. As a result, the Health System could not demonstrate that required suspension and debarment procedures had been performed for applicable vendors. Views of responsible officials and planned corrective actions Management agrees with the finding. The Health System has established procurement policies and procedures; however, the purchases identified in the audit were not consistently processed through the established procurement review process, and the required supporting documentation was not retained. The purchases involved IT equipment, installation, and broadband services necessary for the project. Management believes the vendor selections were supportable as sole-source procurements based on technical compatibility, integration with existing IT infrastructure, continuity of implementation and support, and specialized vendor capabilities. Management determined that the associated costs were allowable. Corrective action will focus on reinforcing departmental compliance with the existing procurement policy, requiring procurement’s involvement before vendor engagement, and ensuring that competitive bidding documentation or an approved sole-source justification is retained for all federally funded purchases. Although the Health System has an established suspension and debarment screening process, certain vendors associated with the Federal program were not included in the screening population. Management will implement a documented reconciliation of federally funded vendors to the screening population, including supervisory review and resolution of any exceptions, to ensure that all applicable vendors are screened and evidence of the screening is retained. No questioned costs were identified, and subsequent to the transaction management verified that none of the vendors tested were suspended or debarred at the time of the transactions.

The Metro Ride Transit Authority has experienced considerable turnover in management staff and the procurement process over debarment and suspension verification was missed. To address concerns and ensure that federal debarment and suspension procedures are properly emphasized throughout the organization, the City has taken steps to strengthen its internal policies. Specifically, oversight of debarment and suspension has been incorporated into both the City’s procurement policy and grant management policy. These enhancements are intended to reinforce compliance and highlight the importance of these procedures throughout the organization.

Finding 2025-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery – Procurement, Suspension, and Debarment Summary of Findings: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002 Prior to entering subawards and covered transactions with the COVID-19 - State and Local Fiscal Recovery Funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the U.S. Department of the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. The County did not have procedures in place to verify entities were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: My office will plan to work with the County Administrator on putting procedures in place for the Department entering into the contract or the County Administrator/County Attorney approving the legal wording of the contract to make sure the vendor is not suspended or debarred. Anticipated Completion Date: December 2026

Finding 2025-002 Procurement, and Suspension and Debarment Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: Management will provide additional training to individuals performing vendor compliance checks and establish internal controls to monitor that vendor compliance checks are being completed accurately and timely. Names of the contact persons responsible for corrective action: Belen Pena, Finance Director. Planned completion date for corrective action plan: November 15, 2026

Management agrees that documentation of suspension and debarment procedures should be strengthened. FYF performed the required checks; however, supporting documentation was not consistently retained. Going forward, applicable SAM.gov verification will be documented and supporting evidence retained in the organization's records, beginning immediately. If alternative verification procedures are required for individuals or vendors outside the United States, the date, method of verification, person contacted, and outcome will be documented and retained. A secondary review will also be incorporated into the process to confirm that required verification and supporting documentation have been completed before applicable transactions are finalized. FYF will incorporate these requirements into its written procedures and communicate them to the relevant finance and operations personnel.

Type of Finding: Material Weakness in Internal Control Over Compliance – Suspension and Debarment; Other Matter Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and retain documentation evidencing the verification performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding is a repeat of prior-year finding 2024-001. The vendor selections identified in the auditor's test sample were engaged prior to November 2025, before the Organization's enhanced verification procedures were implemented. Building on the corrective action plan submitted for fiscal year 2024, the Organization has taken the following corrective actions: ● Beginning in November 2025, the Organization has required completion of a standardized Vendor Eligibility & Compliance Review Form, including documented SAM.gov verification, before engaging any vendor that will be paid in whole or in part with federal funds and before any federal funds are disbursed to that vendor. This procedure continues to be used for all applicable vendors. ● The Organization's Procurement and Vendor Management Policy was formally updated, effective March 3, 2026, as part of the corrective action plan submitted to and approved by the U.S. Department of Labor. The policy explicitly requires suspension and debarment verification, in accordance with 2 CFR 200.214 and 2 CFR Part 180, before a vendor is engaged or paid with federal funds, memorializing the procedures in practice since November 2025. ● All staff involved in procurement have been trained on the updated policy and documentation requirements. ● The Operations Director performs quarterly monitoring of vendor files to confirm that vendor verification procedures are consistently followed and documented. This monitoring has been implemented and is continuing. These controls have been in practice since November 2025 and were formally documented in policy effective March 3, 2026. They continue to be monitored on an ongoing basis to prevent recurrence. The vendor selections cited in the current year finding predate the November 2025 implementation. Name(s) of contact person(s) responsible for corrective action: Cory Finley, Operations Director, with oversight by Brandi Jahnke, Chief Executive Officer Planned completion date for corrective action plan: Implemented in practice as of November 2025 and formalized in written policy effective March 3, 2026. Quarterly monitoring by the Operations Director is ongoing.

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2025 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2025-002 – Procurement and Suspension and Debarment Description of Finding: BCHN did not perform a check at the System for Award Management Exclusions (sam.gov) to verify whether a vendor had been suspended or debarred before being hired. Statement of Concurrence: We concur with the finding above. Corrective Action: The vendor that was selected during the audit was hired in March of 2025. Since that time, BCHN has implemented a process by which all new employees and new vendors are added to the Exclusion Screening LLC database. We engaged Exclusion screening LLC because they check for exclusion and debarment on the OIG, SAM and state exclusion lists monthly, once entered in the system. This process ensures that all new vendors or employees are screened upon hire and are then automatically screened going forward. Completion Date: January 2026 Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

FINDING 2025-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recover Funds – Suspension and Debarment Summary of Findings: Significant Deficiency, Other Matters Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include but are not limited to contracts for goods or services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Due to the U.S. Department of the Treasury's (Treasury) determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Covered transactions in the amount of $2,256,164 were made during the audit period to five vendors. Of the five vendors the County entered into covered transactions with, four included a suspension and debarment clause and/or certification. For one vendor that totaled $45,714, the County did not check the EPLS, nor was a certification collected from the vendor, and a clause did not exist in the agreement with the vendor. Although the County had a policy to include a clause in vendor contracts related to covered transactions, no documentation to verify the County's compliance with the suspension and debarment federal requirement was provided for audit. Contact Person Responsible for Corrective Action Plan: Janet Lloyd, Clinton County Auditor Contact’s Phone Number: 765.659.6330 Contact’s Email Address: jlloyd@clintoncountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county auditor will require the county attorney to review all federal grants to insure all requirements are met and the contract includes the suspension and debarment clause. If the contract does not include the appropriate suspension and debarment clause, the commissioner’s secretary will send the appropriate notification for a certification from the vendor. Once received, the accounts payable INDIANA STATE BOARD OF ACCOUNTS 30 deputy will keep a list of grants approved by the county attorney and check the appropriate language or certification has been received before claims are processed. Anticipated Completion Date: December 31, 2026

FINDING 2025-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Cindy Poore, Director of Finance and Records Contact Phone Number and Email Address: 317-733-2809, cpoore@zionsville-in.gov Views of Responsible Officials: We disagree with the finding. Description of Corrective Action Plan: We received a comment on this during our last audit for 2024. That audit was completed the end of August 2025. The 1 vendor found during this current audit that didn’t have the suspension and debarment verification had been paid prior to the last audit being completed, so there was no way of fixing the issue when it was brought to our attention. This was more of an overlap or timing issue rather than a recurring issue. We have already put a couple of things in place to be compliant with this “finding”. All contracts have a section regarding suspension and debarment added to the verbiage. Vendors that do not have a contract are given to the Deputy Director to look up and print the verification to be kept for audit purposes. Anticipated Completion Date: 8/19/26

Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: • The District has not formalized and adopted a written procurement policy. • In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. • In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for the vendor selection. Corrective Action Plan: The District will develop and formally adopt a written procurement policy addressing procurement activities involving federal awards and the applicable requirements of the Uniform Guidance. The District will establish procedures to document the procurement method utilized and the basis for vendor selection, verify and retain documentation that vendors subject to federal suspension and debarment requirements are not suspended or debarred from participation in federal programs, and ensure that federally funded contracts include applicable federal contract provisions required by 2 CFR Part 200. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: March 2027

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Conservation District January 1, 2025 through December 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring and suspension and debarment requirements, and it did not comply with federal suspension and debarment requirements.Name, address, and telephone of District contact person: Cori Turntine, Operations Director 4422 E 8th Avenue, Spokane Valley, WA 99212 (509) 535-7274 Corrective action the auditee plans to take in response to the finding: The District concurs with Finding 2025-001. The District acknowledges that although staff performed searches of the Federal Audit Clearinghouse for both subrecipients and were aware of the suspension and debarment requirements, the District did not retain documentation demonstrating these verifications, as required by 2 CFR 200.303 and 2 CFR 200.332. The District has taken the following corrective action: Subrecipient Monitoring: District staff performed searches of the Federal Audit Clearinghouse for both subrecipients during the audit period; however, documentation of those searches was not retained. The District has since followed up in writing with both subrecipients and obtained written confirmation that neither subrecipient exceeded $1,000,000 in federal expenditures during fiscal year 2025 and that neither expects to exceed the single audit threshold in fiscal year 2026. This written correspondence is retained in the subaward files. Going forward, all subrecipient monitoring activities - including Federal Audit Clearinghouse searches, single audit determinations, follow-up on audit findings, and management decisions - will be documented and retained in each subaward file at the time the verification is performed. Suspension and Debarment: The District concurs that documentation was not retained for the suspension and debarment verification of the contractor paid $185,998 in federal funds. The contractor was subsequently verified as not suspended or debarred, and no further contracting activity occurred under the affected award. The District has implemented controls requiring verification of suspension and debarment status (via SAM.gov exclusion checks, written certification, or contract clause) before entering into any contract or purchase expected to equal or exceed $25,000, paid in whole or in part with federal funds, consistent with 2 CFR 200.214 and 2 CFR Part 180. Documentation of each verification is retained in the procurement file at the time of award. Project Management System: To provide sustained assurance and to address both components of this finding, the District is implementing a project management system with automated reminders and checklists covering the full life cycle of federal awards, subawards, and procurements. Training: Suspension and debarment and subrecipient monitoring requirements will be incorporated into the District's annual contract and procurement training for all relevant staff. Anticipated date to complete the corrective action: 12/31/2026

Finding 2025-003 I. Procurement and Suspension and Debarment Information on the federal program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Mount Sinai has taken corrective actions to address this issue. During 2025, the Health System created a process to ensure a vendor is not considered suspended or debarred. All existing vendors in the vendor master file, as well as all newly onboarded vendors through our credentialing process, are screened monthly through our designated sanction screening provider. In addition, we have implemented a new monthly manual control to review, confirm, and reconcile our vendor master against the files submitted to our sanction-screening provider. Our Internal Audit team also performs periodic, independent sanction screening checks on a sample of vendors to validate the accuracy and completeness of the third party screening results. Name of responsible official: Franco Sagliocca Corporate Director, Supply Chain Franco.sagliocca@mountsinai.org Projected completion date: December 31, 2025.

2025-002 Auditor’s Recommendation: Convergent Research, Inc. should strengthen its procurement controls to require documented suspension and debarment verification before execution of all applicable covered transactions. The documentation should identify the vendor, date of verification, source used to perform the verification, and result of the search and should be retained in the procurement file. Corrective Action: Convergent Research has incorporated a required suspension and debarment verification step into its federal grant procurement workflow in Ironclad. The workflow documents the vendor, date of verification, source used to perform the verification, and the result of the search. Responsible for Corrective Action: The assigned FRO employee will complete the verification prior to initiating the workflow in Ironclad. Details are documented in Ironclad when the FRO employee initiates the review process. The assigned Convergent compliance reviewer must review all federal-grant-related responses prior to approving the transaction in Ironclad. Anticipated Completion Date: Implemented July 2026 — the Ironclad federal grant procurement workflow is live for all federally funded procurements.

FINDING 2025-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number and Email Address: 317-392-6310; aglackman@co.shelby.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately, which will include implementing a federal procurement policy. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Anticipated Completion Date: December 31, 2026

Community Project Funding / Congressionally Directed Spending – Assistance Listing No. 17.289 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Assistance Listing No. 10.561 Recommendation: We recommend management revise procurement policies to fully align with Uniform Guidance requirements and strengthen procedures to ensure procurement decisions, management approvals, competitive procurement documentation, and suspension and debarment verifications are consistently performed, documented, and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed and updated the financial policies and Procedures Manual as of 01/2026. Procurement procedures have been strengthened. Federal procurement documentation requirements have been incorporated into our process. Suspension and debarment reviews are now being conducted and documented for all new vendors. Procurement files now include approval and compliance documentation. Name(s) of the contact person(s) responsible for corrective action: Stacia Russell Planned completion date for corrective action plan: 01/01/2026

Economic Development Initiative, Community Project Funding, and Miscellaneous Grants – Assistance Listing No. 14.251 Recommendation: We recommend the Organization implement a formal procedure to verify and document suspension and debarment status (e.g., SAM.gov checks) for all covered transactions, including retaining evidence of the verification and incorporating a review control prior to payment or contract approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedures to verify suspension and debarment status for covered transactions, including documenting SAM.gov reviews and retaining evidence of verification prior to contract approval or payment processing. Name(s) of the contact person(s) responsible for corrective action: Jeff Fournier, Finance Director Planned completion date for corrective action plan: June 30, 2026

Management Response: Management has reviewed Finding 2025-001 and concurs with the auditor’s observations. Management recognizes that the exceptions resulted from incomplete procurement documentation and inconsistent use of the required Federal contract provisions and procurement file checklists. Context and corrective actions: • The omission of the Federal contract provisions required by Appendix II to 2 CFR Part 200 was identified through monitoring performed by the grant administrator on behalf of the pass-through entity. Management initiated remediation during the audit period and has amended the affected contracts to include the applicable provisions. Management will also complete a review of active federally funded contracts by September 30, 2026, to confirm that required provisions are included. • One contract lacked documentation demonstrating that the procurement was conducted in a manner providing full and open competition. The vendor relationship predated the grant award; however, management acknowledges that the existing relationship did not, by itself, demonstrate compliance with the applicable procurement documentation requirements. For future federally funded procurements, including procurements involving existing vendors, management will retain documentation of the procurement method, competition performed, and supporting rationale. • For future procurements, the procurement file must include documented evidence of the required price or cost analysis and suspension and debarment verification before contract award or renewal. These requirements will be incorporated into a standardized Federal procurement checklist, as outlined below, with documented review and approval by the Director of Finance and COO. • Management will provide procurement compliance training to relevant personnel by September 10, 2026 and will perform periodic monitoring of federally funded procurement files. Monitoring results will be reported to Board of Directors, and identified exceptions will be tracked through resolution. • The seven exceptions involved four contracts valued below $50,000, two contracts valued between $50,000 and $100,000, and one contract valued above $100,000. These amounts provide context regarding the potential dollar magnitude of the exceptions but do not change management’s obligation to maintain complete procurement documentation and comply with applicable Federal requirements. • Based on the auditor’s procedures, no questioned costs resulted from this finding, and the costs tested were allowable under the grant and otherwise properly supported. Management nevertheless recognizes the importance of addressing the procurement documentation gaps and believes the corrective actions described above will strengthen compliance, improve oversight, and reduce the risk of recurrence. • Management will Develop and Implement Comprehensive Federal Procurement Compliance Checklist. o The Organization has developed a single, comprehensive Federal Procurement Compliance Checklist to be completed for all covered procurements. This checklist ensures compliance with 2 CFR Part 200 (Uniform Guidance) across all identified deficiency areas. The checklist includes: o Federal Contracts Provisions Section (including all contract provisions required by Appendix II to 2 CFR Part 200) o Full and Open Competition Section (including threshold determination, type of procurement method, evidence of public posting, responses, and evaluation of vendors, or a documented Sole Source procurement approval) o Price/Cost Analysis Section (including analysis method, documentation analysis was performed, and evaluation that proposed cost is reasonable). o Suspension and Debarment Verification Section: documented SAM.gov database search, and documentation of escalation if a vendor is found to be on the exclusion list. o The checklist will be integrated into standard procurement workflows to ensure automatic compliance. o Completed checklist must be signed off by the Director of Finance and COO. All documentation referenced in the checklist (competition records, cost analysis, debarment verification) must be retained with the procurement file. o Organization finalized the comprehensive checklist by August 31, 2026 and provided training to all procurement staff by September 10, 2026. The checklist will be required for all new procurements effective September 1, 2026. For all contracts entered into prior to September 1, 2026 that did not comply with the provisions in Appendix II to 2 CFR Part 200, the organization will complete retroactive documentation to the extent possible and execute amendments to incorporate missing Federal provisions by September 30, 2026. Anticipated Completion Date: August 31, 2026 (checklist development); September 30, 2026 (retroactive compliance and amendments) Responsible Party: Daniel Wilmot, Director of Finance