Corrective Action Plans

Sanilac County Community Mental Health Authority Corrective Action Plan September 30, 2025 FINDING NUMBER: 2025-001 Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment, and exclusion is conducted prior to entering a contract Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Name of contact person: Michelle Richards – City Clerk/Treasurer Corrective Action: The city will develop a policy to provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and that no award, subaward, contract or agreement is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2027

Corrective Action Plan: The College concurs with this finding. To mitigate the risk of entering into covered transactions with suspended or debarred vendors, the College is updating and formalizing its suspension and debarment policy, establishing procedures to require and document SAM verification prior to covered transactions under Federal awards, and implementing periodic monitoring to ensure these procedures are performed consistently. Timeline for Implementation of Corrective Action Plan: These process updates will be implemented before the end of fiscal year 2026.

Finding 2025-002 Condition: Suspension and debarment compliance was not verified for nine covered transactions. Corrective Action Planned: Going forward, all contracts using federal funds will be verified. Anticipated Completion Date: Completed Contact: Matt Parent, Town Accountant

Finding Number: 2025-009 ALN Number(s) and Program Title(s): 21.027 – COVID 19: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Views of Responsible Officials and Planned Corrective Action: During the audit, it was noted that for a federally funded contract exceeding $25,000, documentation was not maintained to demonstrate that the vendor was verified as not suspended or debarred through Sam.gov as required by ADE policy and federal regulation. We acknowledge that the required verification was not documented. This occurrence was an oversight in our internal contract review process and a lack of standardized checklist to ensure verification was completed and retained. Upon identification of this finding, we have taken the following corrective action: 1. Immediate corrective action: We are working with the identified vendors to register in Sam.gov. 2. Process Improvement: Documentation of Sam.gov verification will be printed/saved and added to the contract file for all contracts using federal funds over $25,000. 3. Training: Relevant staff responsible for procurement and contract management have been trained in federal suspension and debarment requirements and ADE policy. DESE is committed to full compliance with federal requirements and ADE policy. These corrective actions are designed to ensure that suspension and debarment verification is consistently performed and properly documented for all applicable federally funded contracts going forward. Anticipated Completion Date: Completed. Contact Person: Name: Greg Rogers Title: Chief Fiscal Officer Agency: DESE Address: 4 Capitol Mall, Room 204-A City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-4475 Email Address: Greg.Rogers@ade.arkansas.gov

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness and Instance of Noncompliance Department’s Management Response: Ventura County Health Care Agency (HCA) management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official record, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: HCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO John Fankhauser, HCA Director Implementation Date: March 2026 – Add documentation of suspension and debarment check for applicable contracts.

Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend that the UEC strengthen its procurement procedures to ensure suspension and debarment verification is consistently performed and documented prior to entering into covered transactions funded with Federal awards. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: University Enterprises Corporation (UEC) maintains an established process requiring suspension and debarment verification prior to contract execution. While procurement activities are coordinated in conjunction with CSUSB Procurement, UEC is responsible for ensuring that required verification procedures are completed and appropriately documented for all federally funded transactions. The instance identified represents a lapse in documentation, not a lack of control. UEC has reinforced expectations to ensure verification is consistently documented within the official project file and has strengthened pre-award review procedures to confirm compliance prior to execution. UEC will continue to monitor adherence to ensure consistent application of established controls. Contact(s) Responsible for Corrective Action: Director of Sponsored Programs Planned Completion Date for Corrective Action: June 30, 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Water Conservation Grant Assistance Listing Number: 21.027 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 6, 2026 Planned Corrective Action: The District has designed and implemented policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. The Federal Programs Director and Procurement Clerk will check each vendor exceeding the formal procurement threshold for suspension or debarment.

Finding Reference 2025-003 Personnel Responsible for Corrective Action: Policies and procedures will be supervised by Tracie Thomas (Chief Operating Officer). Policies and procedures will be implemented and maintained by Laura Froese (Accounting Manager), Westen Gehring (Grants Specialist), and Brenna Wilcox (Accounting Specialist). Anticipated Completion Date: Immediately. Views of Responsible Officials and Planned Corrective Action: Concur. Corrective Actions Planned: The Land Institute identified that the exception noted occurred during the initial implementation phase of updated procurement policies developed in response to the FY23 Single Audit finding. The instance was due to a breakdown in timing and communication rather than a deficiency in the policies themselves. To prevent recurrence, The Land Institute has implemented a pre-award procurement control requiring that all sole source justifications and suspension and debarment verifications be completed, reviewed, and approved prior to contract execution and prior to any costs being charged to a federal award. Finance and Grants personnel will verify completion of required documentation before processing payments or coding expenses to federal awards. Training has been provided to relevant staff to reinforce procurement requirements, including timing and documentation expectations. Ongoing monitoring procedures have been implemented to ensure continued compliance.

Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a Suspension and Debarment certification from the contractor. Anticipated Completion Date: April 30, 2026

2025-003 US Department of Education Material Weakness in Internal Control over Compliance Material Noncompliance Suspension and Debarment Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over suspension and debarment requirements. Corrective Action: One City adopted a new procurement policy with thresholds for suspension and debarment procedures and while it was implemented, documentation that the procedures were performed were lacking. In addition, One City has developed a training tool so that all staff who have purchasing authority must participate in the training and understand the requirements to document this procedure. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

Finding: During our audit, we identified that the District failed to check the suspension and debarment status of a vendor with which a new covered transaction was entered. The vendor is not currently registered as being suspended or debarred. Corrective Action: Tulsa Public Schools acknowledges the finding and is implementing corrective measures to update existing policies and procedures to perform the suspension and debarment verification for all covered transactions on a regular basis. Implementation of these corrective measures is expected by June 30, 2026. Owner: Robert Sauceda, Executive Director of Accounting

Finding 2025-006 - Procurement and Suspension and Debarment Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: The City will strengthen its procurement procedures to ensure verification of suspension and debarment status is performed prior to entering into covered transactions funded with federal awards. Management will verify vendors are not suspended or debarred by checking the System for Award Management (SAM.gov) or by obtaining vendor certification prior to awarding contracts. Documentation of the verification will be maintained with the procurement records to ensure compliance with federal requirements. Proposed Completion Date: June 30, 2026

Management response/corrective action plan: Some ARPA expenditures are the result of prior procurements, ongoing contracts, or cooperative purchasing agreements that did not require verification of SAM certification, but were eligible for ARPA funding. Formal bidding includes adding federal language to solicitations and receiving confirmation of active SAM registration. For informal procurements, City departments have been instructed on the requirements when spending grant funds. The City receives federal grant funds regularly for specific projects and understands the federal contracting requirements.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster- Suspension and Debarment Contact Person Responsible for Corrective Action: Jeff Layden Contact Phone Number and Email Address: 765.457.8101, jeff.layden@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Jeff Layden, Director of Operations, oversees our food service department. He will work with our food service vendor to ensure EPLS are checked before awarding any contract for goods or services. Anticipated Completion Date: Immediate. INDIANA STATE

Federal Agency: U.S. Department of Health and Human Services State Department/Agency: Kansas Department of Health and Environment Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Period: NU50CK000549 (7/1/2019 – 7/31/2027) & NU51CK000384 (8/1/2024 – 7/31/2029) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts. Recommendation: We recommend that the Department enhances its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The sub-recipient agreement will be updated to provide space for the date the verification occurred by checking SAM exclusions. Additionally, a copy of the SAMS verification will be downloaded and kept with the executed sub-recipient agreement. If SAMS verification can’t be located, then that will be denoted on the sub-recipient agreement and a signed certification from the contractor will be collected prior to contract execution. This signed certification will be kept with the sub-recipient agreement once the agreement is executed. Name(s) of the contact person(s) responsible for corrective action: Sheri Tubach, Deputy State Epidemiologist Planned completion date for corrective action plan: March 9, 2026

2025-004 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing Number 21.027 Recommendation: We recommend procedures be strengthened to ensure that documentation of verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will implement procedures to ensure verification that vendors receiving payments from federal awards are not suspended or debarred in accordance with 2 CFR §200.214 and 2 CFR Part 180. The Finance Department will require documentation of vendor verification through the System for Award Management (SAM.gov) or equivalent certification prior to processing payments related to federal awards. Documentation of the verification will be maintained with the procurement or payment records, and Finance will perform periodic reviews to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Michael Tucker, Deputy Finance Director Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.

FINDING 2025-004 Finding Subject: Special Education Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district will implement procedures for Procurement, Suspension and Debarment by following the listed steps: 1. Three quotes will be obtained for procurements between $50,000 to $150,000 by the district and contract be awarded. 2. Verification of Suspension and Debarment will be performed by a member of the business office in System for Award Management (SAM) or the district will collect the certification from the entity prior to entering into transactions with the selected entity. Anticipated Completion Date: 3/31/2026

Condition: In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Coronavirus State and Local Fiscal Recovery Funds. Additionally, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Innovative Approaches to Literacy. Planned Corrective Action: A new custom validation warning will be added to the requisitions business process at the buyer approval step to require the Procurement Specialist to verify SAM.gov and attach the results as required for grant funded purchases. This custom validation will ensure that each required consideration of suspension and debarment occurs and is documented in the procurement record. Contact person responsible for corrective action: Director of Procurement Services Anticipated Completion Date: Implemented as of 3/03/2026

Federal Awards Findings Finding 2025‐001 Federal Agency Name: Administration of Children and Families Pass‐Through Entity: Oklahoma Department of Human Services Assistance Listing Number: #93.434 Program Name: Every Student Succeeds Act/Preschool Development Grant Finding Summary: While a control appears to be in place for suspension and debarment, the Foundation could not support a control to verify whether all vendors paid with federal funds were suspended or debarred. For one procurement transaction selected for testing, the Foundation did not perform or document and retain any suspension and debarment verification procedures, such as checking SAM.gov, obtaining vendor certifications, or including suspension/debarment clauses in contracts. Corrective Action Plan: The Foundation has updated controls in place to ensure suspension and debarment verifications are completed on all applicable transactions. Documentation of suspension and debarment check is kept on file in vendor, contractor, or subrecipient files and is completed prior to awarding covered transactions. Responsible Individual: Daphne Peschl, Chief Financial Officer Anticipated Completion Date: March 2026

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures for sole source or limited source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Implementation date: May 31, 2026 Responsible person: Yolanda Davis, Deputy Director, Financial Administration Division

Condition: The City does not have a documented control to perform and retain evidence of suspension and debarment verification (e.g., SAM.gov check or vendor certification) at the time of entering into covered transactions funded by federal awards. Management indicated that vendor eligibility checks are performed as part of standard operating practice; however, documentation evidencing the timing and performance of these checks was not retained. Recommendation: We recommend the City obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Explanation of disagreement with auditing finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will implement a formalized control procedure to ensure compliance with federal suspension and debarment requirements. Specifically, the City will require documentation to be maintained evidencing verification that vendors are not suspended, debarred, or otherwise excluded from participation in federal assistance programs. Verification will be performed through a search of the System for Award Management (SAM.gov) or through vendor certification prior to entering into covered transactions funded by federal awards. Documentation of the verification will be retained with the procurement records.

Condition: Management did not have controls in place to ensure documentation was maintained evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity. Planned Corrective Action: Management concurs with the finding. We acknowledge that, for the awards issued under the Inflation Reduction Act Urban and Community Forestry Program (Assistance Listing Number 10.727), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained by the responsible department. This represents a documentation lapse rather than a deficiency in internal controls as Openlands routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micro-purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $15,000. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and is currently in the processes of executing an update to internal control policies to ensure these checks are maintained prior to entering into a contract by the responsible department as well as updating a clause to all standard vendor contracts requiring a self-certification that they are not excluded, debarred, or suspended from entering into covered transactions with the federal government. Contact person responsible for corrective action: Paul Spector (Director of Finance) Anticipated Completion Date: January 31, 2026

Condition: Suspension and debarment compliance was not documented for four covered transactions. Corrective Action Planned: The Town Administrator who serves as the Town’s Chief Procurement Officer will run the verification upon the approval of any agreement or contract with a vendor. The verification will then be run annually (end of December) for any vendors who still have open projects to be paid. The verification will be kept with the vendor and procurement file for reference if needed. Anticipated Completion Date: Completed December 30, 2025 Contact: Chad Lovett, Town Administrator