Corrective Action Plans

February 19, 2026 Christina Schaub, CPA Roslund, Prestage & Company P. C., CPA's 525 West Warwick Drive, Suite A Alma, Ml 48801 RE: Corrective Action Plan — City of Sault Ste. Marie — Single Audit Fiscal Year: 2025 M unicipality Code: 172010 Finding Number: 2025-001 Ms. Schaub: The City of Sault Ste. Marie was notified of a significant deficiency in its 2025 Federal Awards single audit report. Finding Type: Significant deficiency in internal control over compliance Program: ALN 97.044 — Assistance to Firefighter Grant . Grant Number EMW-2022-FG-01118 • Grant Number EMW-2023-FG-03417 • Grant Number EMW-2023-FG-02529 Criteria: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation. Managements Response/Corrective Action Plan: The City of Sault Ste. Marie has instituted the following measures to remedy this deficiency to be implemented immediately. 1. Management learned of this deficiency in response to a request for documentation of a check for debarment in connection with the single audit field work in October 2024 and again with the current single audit. Upon further inquiry, City staff didn't have documentation of this kind. This task slipped through the cracks because a process was not in place to ensure it was completed. 2. In reference to the City's Uniform Guidance Policies, most recently approved by the City Commission on February 17, 2025, page 44, the City will include a suspension/debarment clause in all written contracts in which the vendor will certify that it is not suspended or debarred. Alternatively, the city may request vendor/contractor sign a certification regarding suspension or debarment. Executed certificates and procurement files will be retained by the City Clerk's office. This language was in the policy but was not implemented. 3. A sample certificate is provided on page 53 of the unform guidance policy. This sample certificate, if completed, would have provided evidence but was not implemented. For future contracts, this certificate will be completed prior to the bid award and documentation that it has been completed will be required for future City contracts that are part of a federal grant award. 4. If for any reason this signed certificate is not available prior to the award bid recommendation, City staff will check the vendor's status on Sam.gov and will document the results in the narrative of the memo. This will be required for all contracts related to federal grants. City staff will be provided instructions about how to check the status as by the State of Michigan in the following link... https://www.michigan.gov/msp/-/media/Proiect/Websites/msp/EM HSD/grants2/instructions for checking for excluded debarred contractors revised 72020.pdf?rev=0a928fb6b4b54253b2a627f1eb70dcd8&hash=31DC61AC1AB1 E38D5A84952C43D27F82 5. Going forward, City staff will add a note to the narrative of the agenda memo in BoardDocs to state whether the City has a certificate or found that the vendor was not suspended or debarred a nd provide documentation to be attached to the memo for all bid award Recommendations. For example, we might indicate that the vendor/contractor was checked on Sam.gov and the contractor was not suspended or debarred and then follow up with a signed certificate when the contract is signed. Alternatively, a copy of the certificate, if separate from the contract, can be attached to the requisition in the P0 module. 6. This updated process will be shared with all project managers and grant administrators, along with staff in Finance and Clerks offices, so that we can ensure it is completed with each contract a nd project managers are supported during the busy construction season. 7. When bid award agenda memos route through Finance, they'll be reviewed to ensure this task has been completed and documentation is provided. This corrective action is being implemented as of this date and is expected to fully resolve the deficiency. Thank you for this opportunity for improvement. Sincerely, Kali Perron Finance Director/Treasurer

Congressional Directives – Assistance Listing No. 93.493 Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CAPECO will obtain time-stamped verification support from SAM.gov to ensure that potential contractors are free from debarment and suspension prior to executing the contract. Name(s) of the contact person(s) responsible for corrective action: Paula Hall, CEO and/or Katie Smith, CFO Planned completion date for corrective action plan: Effective Immediately

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement We will be updating the Policy 6325 for Micro purchases from $10,000.00 to $50,000.00. We are in policy review now. Suspension and Debarment All new vendors entered into the system are checked by the Corporation Treasurer through the Office of Inspector General search, printed and kept on file in the Corporation office. Further, all vendors used by the Food Service department have been updated to be current. Anticipated Completion Date: March 1, 2026

Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu

Management did not have documented controls in place to ensure contractors are not suspended or debarred from participating in federally funded activity Planned Corrective Action: To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following corrective actions: 1.Policy Enhancement: The procurement procedure has been updated to explicitly require saving and retaining a time-stamped screenshot or PDF confirmation of each SAM.gov verification showing the verification date and results. Where applicable, contractors subject to 2 CFR 200.214 must also provide a self-certification statement within the executed agreement. 2.Centralized Recordkeeping: Verification evidence will be maintained in both the individual contract file and the centralized grant management system. 3.Annual Training and Refresher: Procurement and grants management staff will participate in annual training to reinforce 2 CFR 200.214 requirements and best practices for documentation and record retention. Contact person responsible for corrective action: Ian Kile, Director of Internal Control, and Chiyoko Yokota, Chief Financial Officer Anticipated Completion Date: 2/28/26

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) – Suspension and Debarment Contact Person Responsible for Corrective Action: Jeremiah Hruschak, Assistant Director of Financial Services; 260-0100x1006; jhruschak@eacs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: East Allen County Schools will establish and document a formal internal control procedure to ensure compliance with federal suspension and debarment requirements for all covered transactions (contracts, subawards, or purchases ≥ $25,000 using federal funds). The procedure will include the following: • Prior to entering any covered transaction expected to equal or exceed $25,000 with federal funds, the purchasing or accounts payable staff will verify the vendor’s status by checking SAM.gov Exclusions. • Zoom training with Directors and Grant Coordinators to verify SAM.gov for vendor disbarment. A screenshot or PDF export of the SAM.gov search results (showing the vendor is not excluded) will be obtained and attached to the purchase requisition or contract file. If not listed on SAM.gov, coordinators will request signed letters from vendors regarding status. • A standardized suspension and debarment verification checklist will be incorporated into the purchasing process for all federal-fund expenditures meeting the threshold. • Annual training (pending employee turnover) will be provided to staff involved in federal purchasing/procurement on the suspension and debarment requirements and the new verification process. • The Assistant Director of Finance perform periodic reviews of a sample of federal purchases ≥ $25,000 to confirm compliance. These controls will prevent future noncompliance with 2 CFR 180.300 and 2 CFR 200.214. Anticipated Completion Date: March 31, 2026

Views of Responsible Officials and Corrective Action Plan 2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University The University acknowledges the need for consistent application of policies and procedures to ensure compliance with 2 CFR 200.214. The university performed a root cause analysis and determined that these identified issues were human error due to the manual nature of the established process. The University reviewed the three identified vendors and concluded that they were not debarred at the time of the transaction. Outlined below are steps that the university will take or have taken to improve our processes and procedures:  As of June 2025, Yale has implemented the Supplier Gateway Portal, introducing an enhanced, automated process for supplier onboarding. New suppliers established through the portal are automatically screened for debarment without manual involvement. Subsequently, the supplier’s information is transferred weekly to the Visual Compliance system, which performs continuous debarment monitoring. Yale is proactively notified via email should any changes in a supplier's status occur.  The university provided training to the full team responsible for these activities with the rollout of the Supplier Gateway Portal. This was completed June 2025. University contact: Rodney Brunson, Director, Accounts Payable & Payment Services Rodney.Brunson@yale.edu

2025-006 Procurement, Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: Our auditors recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. Our auditors also recommends the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to audit findings regarding procurement, suspension, and debarment practices within the Special Education Cluster (IDEA), the District has initiated and is implementing a comprehensive enhancement of policies and procedures to ensure full compliance with Uniform Guidance (2 CFR Part 200) and the District's Purchasing Policy. We are conducting thorough evaluation of all procurement procedures specific to IDEA-funded purchases and have developed enhanced documentation protocols ensuring all procurement transactions are properly documented and maintained in accordance with federal and district requirements. Recent procurements reflect significantly improved documentation practices. We have created standardized procurement checklists and templates to promote consistency across all IDEA-related purchases, and staff now utilize these tools routinely. Regarding suspension and debarment verification, we have established a formal verification process requiring designated staff to check the System for Award Management (SAM.gov) database prior to executing contracts or purchase orders with vendors using IDEA funds, and compliance is now being consistently achieved. Documentation of these verification checks is maintained in procurement files as evidence of compliance. We have implemented training for all staff involved in IDEA procurement, and staff report increased awareness and confidence in performing these checks. Additionally, we have designated the Director of Business Services and Special Education Director as dual reviewers for all IDEA procurement transactions exceeding established thresholds, creating additional oversight that has already prevented potential compliance issues. Regular quarterly internal audits are being conducted, and initial audits indicate substantial improvement in both procurement documentation and suspension and debarment verification practices. These measures are strengthening our procurement framework for the Special Education Cluster and ensuring consistent compliance with federal regulations. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2026

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION AND GRANT NUMBER AC-22-0096, GRANT PERIOD - YEAR ENDED JUNE 30, 2025 Name of contact person: Mayor and City Council Corrective Action: The city has scheduled a meeting with engineers to discuss this issue and to make sure that, before the next federal funded project is started, all parties understand the procurement and suspension and debarment requirements. We intend to ensure that the procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchases of goods or services is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2026

Finding 2025-002 Procurement Policy – Procurement, Suspension, Debarment Name of responsible official: Owen Astbury- Selectboard Chair Corrective action: The municipality is working to adopt policies and procedures in accordance with federal regulations. Anticipated completion date: June 30,2026

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 16, 2022, to administer the federal grants to ensure that the Town would comply with allfederalprogram requirements. The Town was led to believe that they were in compliance with all federal program requirements. This is the second year of both federal grant programs, and the Town is just being made aware of the suspension and debarment requirement. It should be noted that all contractors and the consultant are not on the suspension and debarment lists.

CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This policy, which includes a Conflict of Interest section, was updated to reflect a decrease of the micro-purchase threshold from $50,000 to $10,000, clarifies that the SAM.gov check for suspension and debarment will occur prior to contract execution with the contractor, and the SAM.gov check will be documented with the date it was conducted. The updated CIF Procurement Policies & Procedures will be approved by the Board of Directors.

Special Education Cluster - Suspension and Debarment The finding is a material weakness in internal control over federal awards and material compliance finding due to the District not retaining documentation related to suspension and debarment of vendors. The District will continue to train staff on the District’s procurement policy and the requirement to retain documentation for procurement decisions, including documentation of suspension and debarment verifications.

We have reviewed the findings and recommendations in the audit for Fiscal Year 2025. The following are our planned corrective actions for the identified issues: Finding 2025-002: Procurement Procedures. - Change in procedure for Treasurer review of contract awards when presenting to Council to include checking vendor for suspension or debarment and document. - Update pruchasing policies and procedures to add requirement to check for vendor suspension or debarment prior to contract award. We appreciate the constructive feedback provided by your firm which provides us with the opportunity to improve and grow.

The District will review all vendors with expenditures of $25,000 or more within the SAM.gov to determine if they are published as ineligible.

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Pass-Through Entity: State of Wyoming Office of State Land and Investment Board (OSLI) Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: We did not have a written procurement policy in place that aligned with all federal regulations. We also did not review vendors to ensure that they were not debarred, suspended, or otherwise excluded from participating in federal awards. Corrective Action Plan: We will review and update our procurement policy to align with all federal requirements, as well as revise our vendor policy to ensure vendors that are used for federal awards to ensure that they are not debarred, suspended, or otherwise excluded from participating in Federal awards. Responsible Individuals: Jim Cussins, CFO Anticipated Completion Date: March 31, 2026

HHC was in the process of adding a new site in the Steelton area, due to additional need that had been identified for our services. HHC had been the recipient of a Federal Grant- American Rescue Act- Capital Grant and had identified several options for the use of such funds; however, none of those options resulted in a viable use of these funds. It was determined late in the Steelton building project to utilize the American Rescue Act- Capital Grant funds to support this project. Due to the timing and the fact that the General Contractor had already been selected and work had already started on the project, HHC did not proceed with an Exclusion List check to ensure that none of the individuals on the project (contractors and sub-contractors) were not prohibited from being involved in this project. HHC’s Procurement Policy does require review of the Exclusions List for all projects supported by Federal Grant Funds. HHC has reviewed our Procurement Policy and determined that no revisions of the policy are required at this time. HHC has already completed a retroactive review of the Exclusions List of all Contractors and Sub-contractors that were involved in the Steelton Project and found that there were no identified exclusions. This review was completed in September 2025. HHC is committed to future compliance with the review of the Exclusions List for all capital projects whether or not they are supported by Federal Grant funds.

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