Corrective Action Plans

The Town of Lynnfield, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDIT 2025-001 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend procedures be implemented to ensure that the verification of vendors’ suspension and debarment status is documented 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 Town has implemented procedures requiring documentation of vendor suspension and debarment verification prior to the execution of transactions involving federal funds. Staff responsible for procurement and accounts payable have been instructed to verify vendor eligibility through the System for Award Management (SAM.gov) and retain documentation of the verification in the applicable procurement or payment file. Name(s) of the contact person(s) responsible for corrective action: David Castellarin Planned completion date for corrective action plan: June 30, 2026

Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal System for Award Management (SAM.gov) prior to contract execution. Anticipated Corrective Action Plan Completion Date: April 1, 2026 Contact Information: For additional information regarding these corrective actions, contact Stephen Bauer, CEO at 414.345.3240. Stephen Bauer CEO Guest House of Milwaukee

2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. Documentation of verification through SAM.gov or equivalent methods could not be provided by management. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors used on the project funded with federal awards. Recommendation: We recommend the Organization ensure the staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already established policies that the Organization has regarding such requirements. Corrective Action Plan: The contract associated with this finding was signed on January 24, 2025, before the 2024 financial audit was finished, so before the organization made changes to their procurement policy. Since then, the organization has reviewed its existing procurement policy, and updated it as necessary and will ensure that for future projects, the procurement policy will be carefully followed, including verification through SAM.gov. Staff involved in projects and procurement will receive training regarding the policies and the federal guidelines for federally funded projects. Contact Person Responsible: Interim Director of Finance /CFO Completion date: June 30, 2025

Community Project Funding (CFP) Program – Assistance Listing No. 14.251 Recommendation: We recommend the City formalize suspension and debarment compliance procedures in a written policy and ensure verification is performed and documented for all covered transactions prior to entering into contracts funded by Community Project Funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will develop and adopt a written policy addressing suspension and debarment requirements applicable to federal programs, including Community Project Funding. The policy will define required verification procedures and documentation standards. City staff will perform and retain evidence of suspension and debarment verification for all covered transactions prior to entering into federally funded contracts. Name of the contact person responsible for corrective action: Zach Doud Planned completion date for corrective action plan: December 31, 2026

Condition: Suspension and debarment compliance was not verified for nine covered transactions. Corrective Action Plan: The Town will verify that all vendors paid with ARPA (SLFRF) funds are not suspended or debarred by checking sam.gov prior to payment. Documentation of the verification will be retained with the supporting payment records. Anticipated Completion Date: June 30, 2026 Contact Information: Eric A. Kinsherf, CPA, Town Accountant

2025-004 Suspension and Debarment Corrective action planned: Management shall ensure that the procurement staff perform vendor checks prior to entering into procurement arrangements with vendors. Staff will retain documentation that the checks were performed and when they were performed. In addition, staff will update these checks on an annual basis. Management shall implement the following procedures to ensure compliance. • Standardize a vendor verification checklist for all procurements meeting the threshold. • Integrate checks into procurement workflows so they are not an afterthought. • Train procurement staff on SAM.gov use and due diligence criteria. • Maintain a centralized procurement log with dates, results, and responsible parties for audit readiness. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

Finding 2025-001 Corrective Action Plan: Management will complete the retrospective review of appliable federally funded procurements to ensure required suspension and debarment verifications are documented and retained in the procurement files. In addition, Procurement supervisory personnel will implement periodic compliance reviews to verify that required SAM.gov verifications are completed, documented and maintained prior to contract execution. Additionally, the Internal Audit team will conduct random reviews of federally funded procurement files to ensure compliance with the SOPs and to verify that proper documentation is maintained. Expected completion date: September 30, 2026 Point of contact for Follow-Up: Diana Hayashi, Buyer Supervisor II Rita Aquiningoc, Program Coordinator III Janet Taitano-Arroyo, Internal Auditor

The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirements. Responsible Persons: Police Chief/Finance Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

Finding Number: 2025-001 – Suspension and Debarment Planned Corrective Action: Management concurs with the finding. The organization will implement the following: • Update our internal procedures checklist for federal awards to include performing and documenting suspension and debarment checks in SAM.gov prior to executing any agreements funded with CDFI ERP Award, or any other federal award, funds. • Include the required suspension and debarment representation into all contracts, including loan agreements and promissory notes. Management has already performed a retrospective review of CDFI ERP-funded transaction and determined no other additional corrective actions are necessary. Persons responsible for Corrective action Plan: Steve Holmes (Controller), and Laura Hensley (Compliance Manager) Anticipated Date of Completion: May 22, 2026

Action taken in response to finding: The Club will implement procedures to document and retain evidence that suspension and debarment verification is completed prior to engaging contractors by printing and dating the SAM.gov listing and retaining in audit files. Name(s) of the contact person(s) responsible for corrective action: Julie Adelmund Planned completion date for corrective action plan: 5/13/2026

Corrective Action Plan Tri-County Regional Planning Commission respectfully submits the following corrective action plan for the year ended December 31, 2025. The findings from the Single Audit Report Year Ended December 31, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Procurement, Suspension, and Debarment Highway Planning and Construction – 20.205 Contact Person: Andrew W. Bomberger, AICP, Executive Director Recommendation: The Commission should review policies in place over Procurement, Suspension, and Debarment and establish procedures to identify clear roles for the review of vendors prior to a contract. Action: The Commission is in agreement with the finding and will ensure that internal controls over the suspension and debarment review are operating as designed. SAM.gov, or other accessible database, will be used by the Executive Director, or Associate Director or Administrative Coordinator as assigned, in future suspension and debarment reviews prior to contracting with vendors. Date for Completion: 5/14/2026

2025-001: Lack of Documentation of Suspension/Debarment Testing at Time of Procurement Federal Department: Department of Treasury Assistance Listing #: 21.027 Internal Controls Material Weakness & Noncompliance Category of Finding – Procurement, Suspension, and Debarment Name of contact person: Nancy Cashman, Executive Director Corrective Action: Management plans to ensure, with all contracts, that the vendors sign a statement, either included in the contract or as a rider to the contract which confirms that they are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by a federal department or agency. Completion Date: May 5, 2026

East Rio Hondo Water Supply Corporation will implement procedures to verify vendor eligibility through SAM.gov prior to awarding contracts or processing payments related to federally funded projects. Documentation of the verification will be maintained with the related disbursement or procurement records. Responsibility for performing and documenting the verificaiton process will be assigned to accounting personnel and reviewed by management. Implementation of these procedures will begin in 2026.

Management will improve procurement compliance controls by: • The verification and retention of support that vendors are not suspended or debarred has been moved to be part of the accounts payable onboarding process of vendors and maintained in the vendor’s file in the accounting system. • Implementing a standardized checklist or form documenting that the verification that a vendor has not been suspended or debarred prior to contract execution and/or payment. • Providing refresher training to staff involved in procurement and accounts payable on documentation requirements.

Actionable plan: The Organization will establish and implement formal policies and procedures requiring staff to research, verify, and document the suspension and debarment status of all vendors for covered transactions. This verification will take place prior to entering into any contracts with vendors, ensuring compliance with 2 CFR 200.214. Responsible individual: Madeline Henriquez, Executive Director Anticipated completion date: Immediately, April 1, 2026

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.

Finding 2025-003 – Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The Town will implement procedures to verify contractor eligibility for all applicable procurements by documenting searches performed in the System for Award Management (SAM.gov) or obtaining certifications from contractors. Contract templates will be updated to include required suspension and debarment certification language, as applicable. Documentation of verification will be retained in procurement files. Responsible Official: Clerk/Treasurer Planned Completion Date: May 2026

The Town of Spruce Pine will implement written procedures requiring verification of contractor eligibility prior to awarding contracts or subawards funded with federal assistance. Procedures will include verification through SAM.gov, collection of contractor certifications, or inclusion of suspension and debarment certifications within contracts. Staff involved in procurement and project oversight will receive training on Uniform Guidance requirements, including suspension and debarment compliance.

2025-001 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 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 District has begun strengthening its procurement and accounts payable procedures to ensure vendor suspension and debarment verification is completed and documented before any contract is executed or transaction is processed with federal funds. Going forward, staff will verify vendor eligibility through SAM.gov or other required sources, retain evidence of the verification in the contract or procurement file, and use a standardized checklist to document compliance. The District will also review internal procedures with relevant staff and reinforce this requirement for all applicable federally funded purchases and contracts. Name(s) of the contact person(s) responsible for corrective action: Director of Finance, in coordination with Superintendent and Assistant Superintendent’s Office. Planned completion date for corrective action plan: April 30, 2026

Condition: The CMHSP did not perform a reveiw 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. Corrective Action: Those involved in managing the grant will ensure that a suspension and debarment review is conducted for any vendor with whom an agreement is established prior to any work being conducted utilizing grant funding. Staff responsible: Kristyn Kostelec, Grant Manager and Kelly Jenkins, Chief Operating Officer Anticipated completion date: immediate, as new contracts occur.

The Town acknowledges the lack of written policy and procedures for expending federal funds and insuring vendors are not debarred, suspended, or ineligible to receive federal funds. The Town shall (1) Update its written procurement policies and procedures to require verification of vendor eligibility through SAM.gov prior to awarding any contract or issuing any purchase order funded with federal awards. (2) Require procurement staff to retain documentation of the suspension and debarment verification. (e.g., dated SAM.gov search results or vendor certifications). (3) Provide training to relevant personnel on federal procurement requirements including suspension and debarment compliance under 2 CFP Part 200.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Action: The City ensures that debarment requirements for prime contractors and subcontractors are met prior to the use of federal funds. Moving forward, the City will expand compliance efforts to include all required parties. Staff will be educated on these requirements, and the City will work with engineers to ensure debarment language is included in project bidding documents and supplementary conditions. Proposed Completion Date: Immediately

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.