Corrective Action Plans

Corrective Action Plan: Effective September 2025, the District has implemented a procedure to perform this review on vendors associated with federal grants annually. Responsible School District Official: Jennifer Mulligan, Director of Business and Finance Completion Date: September 30, 2025

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

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. Kayla Quick, Accounts Payable Clerk. 6/30/2026

Action taken: A new secretary (A. Chittenden) was hired in February and wasn't aware this needed to take place. It was assumed that Capital Region BOCES (the district contracts food services management through them) was performing that on the district's behalf. Ms. Chittenden has been made aware that this is part of her job duties. Anticipated completion date: immediately

OBI will update current purchasing and procurement policy to specifically address the acquisition of property or services using federal grant funds to ensure adherence to Federal procurement standards in 2 CFR Part 200 sections 200.317-200.327. Our policy will outline requirements regarding vendor selection and vendor qualification. It will address the simplified acquisition threshold, micro purchases threshold, and the formal procurement methods that must be adhered to when the value exceeds those thresholds. The policy will include when sealed bids, proposals/requests for proposals are required and when sole source procurement is appropriate and allowable. Whenever sole source procurement is used, the rationale will be documented and approved. Our policy will include language requiring that all vendors and contractors paid using federal funds be checked for federal suspension & debarment using Sam.gov. Vendors found on the exclusion list will not be paid using federal funds. The policy outlines requirements for written approvals and documentation of all procurements. Additionally, OBI has implemented procedures to ensure that at the point of receiving the Notice of Award, any federal money or grant awarded to OBI will be immediately communicated to the CFO, Controller, and the Senior Accountant. Person(s) Responsible: Senior Accountant with review and approvals from Controller and CFO Estimated Completion Date: January 31, 2026

Effective July 1, 2025, The Executive Director of Business & Human Resources, Kevin J. Polunci will review and verify the eligibility of vendors that participate in Federal assistance programs on an annual basis. The District will review the eligibility of potential vendors that participate in Federal assistance programs and compare invoices to bidding/contracts prior to payments.

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

Views of Responsible Officials and Planned Corrective Action: The District acknowledges the finding and agrees with the recommendation. To address this issue, the following corrective actions will be implemented: The Business Office will verify all vendors used in federally funded programs at least once annually and prior to disbursing funds o Persons responsible: Michele Hogan and April Young o Anticipated Completion Date: This process will be completed by June 12th, 2026 ● Staff will review both 2 CFR Section 200.214 and 2 CFR Part 180 for understanding and compliance o Persons responsible: Michele Hogan and John Lybert o Anticipated Completion Date: This will be completed by September 30, 2025

Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.

The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.

In response to the findings of the Annual Audit for Indiana Agriculture Education, Inc. dba Indiana Agriculture & Technology School, our business process includes a review on SAMS.GOV to ensure that payments from any federal grant are not made to any person or business entity that is listed as suspended, excluded or disbarred. The review of each payment is made prior to issuing an order for goods or services, by our corporate treasurer, currently Kendell Sanders, and is confirmed as approved for payment to our Executive Director prior to issuance of a voucher for payment and subsequent reimbursement with federal funds. This has been included in our internal financial procedures policy documents effective October 15th, 2015, by action of the Board of Directors. The policy shall be reviewed annually. Allan R. Sutherlin Board President Indiana Agriculture Education, Inc

2025-001 - Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through Al-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct Management's View and Corrective Action Plan The University concurs with this finding. On June 25, 2024, the University encountered multiple job failures due to the expiration of a Java Security Certificate. As a result, the file which was to be submitted to the University's third-party servicer for new vendor suspension and debarment screening was not transmitted. The University's Data Center has procedures in place which should have ensured that the vendor file was resubmitted to the third-party servicer once the University's server-related issues were resolved. Unfortunately, due to incorrect documentation in the production operations system (a.k.a. runbook) the vendor file was not resubmitted. Upon further review it was determined that over the course of the fiscal year this was the only incident where the file failed to be transmitted to the servicer. The 25 vendors not screened as a result of the job failure represented less than 1 % of the 3,860 new vendors successfully transmitted and screened by the third-party servicer during the 2025 fiscal year. To ensure that any system issues affecting the daily transmission of the vendor files to the third-party servicer are promptly resolved and new vendors are checked for suspension and debarment, the Information Technology team will enhance the procedure documentation (runbook) and team members will receive cross training. Both the update to the runbook and cross training of team members will be completed by the end of November 2025. University Contact Lyndsay King Associate Vice President, Finance and University Controller Office of the Controller 617-552-3363

2025-004 – Lack of Documentation for SAM.gov Exclusion Checks. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Village did not retain documentation to support that the exclusion checks were performed for vendors. As a result, there is no evidence that the Village verified whether these parties were suspended or debarred prior to entering covered transactions. Auditor Recommendation. We recommend that the Village 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 Village 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. Ross Wilson, Village Clerk/Treasurer. Anticipated Completion Date: February 2026.

2025-005 Suspension and Debarment Corrective action planned: OMC currently has a policy and procedure for vendor exclusion checks prior to executing contracts. This finding appears to be an incidental omission that resulted in no excluded vendors being identified. In one case, the vendor was an existing one for many years. The CFO/Designee will monitor to assure exclusion checks prior to CEO signing any contracts or purchase orders with any vendor over $25,000 per year and will update policy as necessary in accordance with regulations. OMC will seek HRSA guidance on periodic review of existing vendors Anticipated completion date: September 30, 2025 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025. The SVP/CFO Mary Maziejka will be responsible for development and implementation of the policy.

U.S. Department of Health and Human Services Material Weakness in Internal Controls over Compliance and Material Noncompliance: Procurement, Suspension and Debarment Recommendation: CLA recommends the Alliance to develop the procurement policy compliance in with Uniform Guidance, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Alliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HIV Alliance updated our Procurement Policy to comply with the federal guidance using the recommendation provided by CLA. The Board of Directors voted toapprove the updated Procurement Policy in June of 2025 and we implemented the updated policy on July 1, 2025. Name(s) of the contact person(s) responsible for corrective action: Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION, GRANT No. AM-23-0295, YEAR ENDED JUNE 30, 2024 Name of contact person: Mayor and City Council Corrective Action: The city procurement policy will be updated to include references to all federal procurement standards and requirements. All directors and relevant individuals will be trained on the updated policies. Proposed Completion Date: December 31, 2025

2024-5 Suspension and Debarment Verification Recommendation: We recommend that the Borough establish and implement procedures to verify and document that all vendors and contractors receiving Federal funds are not suspended or debarred prior to entering into covered transactions. Acceptable procedures include checking vendor status on the SAM.gov website and printing or saving verification documentation, or obtaining vendor certifications confirming compliance. This review should be documented and retained for audit purposes. Management's Response: Management acknowledges that verification of vendor eligibility is an important control to ensure compliance with Federal requirements. The Borough will develop and implement procedures to verify and document the suspension and debarment status of all vendors and contractors receiving Federal funds. Going forward, management will perform and document a check of each applicable vendor on the SAM.gov website prior to entering into a contract or processing payment under a Federal program. Copies of the verification results will be retained as support.

Response acknowledges the material audit adjustment to the Organization’s financial statements. This situation is related to internal controls over compliance with suspension and debarment requirement. Management has improved procedures related to the future compliance with suspension and debarment processes for contracts. We also do not anticipate hiring any other contractors in the foreseeable future since our capital campaign building project is not completed.

Condition: Suspension and debarment compliance was not verified for four covered transactions. Corrective Action Planned: The Town will implement procedures to include a suspension and debarment certification in all federal contracts that are considered covered transactions to ensure that the contractors are eligible to receive federal funds and not excluded or disqualified from doing business. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawyer, Town Administrator

U.S DEPARTMENT OF TREASURY COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027, Grant Period - Year Ended December 31, 2024. Planned corrective Action: The District will review federal suspended and debarred listings prior to awarding any projects. Person Responsible: BCCD Manager Anticipated Completion Date: 11/12/2025

Views of Responsible Officials and Planned Corrective Actions: Management agrees documentation must be retained. Corrective Action: Management has implemented a formal process to document vendor eligibility verficiation. As of FY 2025, all vendors are revewied in SAM. gov prior to payment or contract execution, and a screenshot or PDF of the verification is saved to the Vendor Verification Log. The Grants & Finance Manager maintains this documentation as part of the procurement file.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Conservation District January 1, 2024 through December 31, 2024 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: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal reporting, suspension and debarment requirements. Name, address, and telephone of District contact person: Cori Turntine, Operations Manager 4422 E 8th Avenue, Spokane Valley, WA 99212 (509) 535-7274 Corrective action the auditee plans to take in response to the finding: We concur that the FFATA Subaward Reporting System (FSRS) reporting was not completed within the required timeframe. Upon identification of the reporting gap, the required subaward reporting was completed. We also concur that documentation was not retained for the suspension/debarment check for one contractor. The contractor was verified as not suspended or debarred; however, the documentation was not included in the project file. To strengthen internal controls and prevent future occurrences, the District is implementing the following corrective actions: • Policy & Procedure Updates: Updating federal grant management and procurement procedures to formalize FFATA reporting timelines, suspension/debarment documentation requirements, and staff responsibilities. • Centralized Tracking: Establishing a centralized tracking process for all applicable subawards, including FSRS reporting deadlines. • Documentation Standards: Requiring and documenting suspension/debarment checks at the time of procurement or subaward execution, consistent with 2 CFR 200.214 and related requirements. • Training: Incorporating suspension and debarment requirements into annual contract and procurement training. • Periodic Internal Review: Implementing internal reviews of a sample of federally funded contract files to verify that reporting and eligibility documentation are timely and complete. Anticipated date to complete the corrective action: The framework will be in place by December 31, 2025.

Force Detroit will monitor compliance through: ● Vendors/grantees must submit regular financial and programmatic reports, including expenditures, progress toward goals, and any issues encountered. ● Reports will be reviewed for accuracy, completeness, and alignment with the approved budget and program plan. ● Site visits to verify program activities, financial management practices, and overall compliance. Findings will be documented, and any deficiencies will trigger the Corrective Action Plan. ● Review of financial and programmatic documentation ● Verification of debarment and good standing with regulatory bodies ○ Vendors/grantees must provide confirmation that they are not debarred, suspended, or otherwise restricted from receiving federal funds.