Corrective Action Plans

Auditor Description of Condition and Effect. During our single audit testing, it was determined that there was no process in place to verify that vendors with transactions in excess of $25,000 were not suspended or debarred. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Auditor Recommendation. We recommend that the Organization review its policies over suspension and debarment review to ensure that they are contracting with allowable vendors. Corrective Action. For Federal grants, management will implement a system for verifying that all vendors or subrecipients with transactions exceeding $25,000 are not suspended or debarred by the federal government, ensuring full compliance with federal regulations and minimizing the risk of using prohibited vendors. A mandatory check against the System for Award Management (SAM) database for suspension and debarment status will occur, with a printout or screenshot of the results maintained. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. January 31, 2025

Finding Number: 2024-001 Condition: The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Planned Corrective Action: Upon notification of the deficiency, a root cause investigation on the actions involved during the Grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the Finance Department, which includes Purchasing Division, Operating Departmental procurement requestors using federal grant awards and all Accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements. Contact person responsible for corrective action: Michael Kennedy, Finance Director Corey Jarocki, Deputy Finance Director Anticipated completion date: 11/19/2024

M anagements 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. Upon further i nquiry, 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 5, 2024, page 43, 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 51 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/gra nts2/instructions for checking for excluded debarred contractors revised 72020.pdf?rev=0a928fb6b4b54253b2a627f1eb70dcd8&hash=31DC61AC1AB1E38D5A84952C43D27 F82 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 and 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 and 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, Kristin M. Collins Finance Director/Treasurer

Management at the Central Maine Growth Council is aware of its responsibility under 2 CFR 200.516(a) as it relates to the requirements to perform control activities related to suspension and debarment. • All recipients of expenditures under federal grants will be compared to the Office of Inspector General’s Exclusion Database to help ensure they are permitted to receive federal funding. This verification process will be documented and retained. • A written formal procurement policy and conflict of interest policy will be established. Responsible party: Garvan Donegan, Director of Economic Development and Strategic Projects (207) 680-7300 Anticipated completion date: December 31, 2024.

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Completion Date: September 30, 2024 Responsible Party: Michaela Arndt, County Clerk

Program: AL 21.027 - COVID-19- Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: August 16,2024 Responsible Party: Dixon County Board of Supervisors: Don Andersen, Deric Anderson, Roger Peterson, Neil Blolun, Lisa Lunz, Terry Nicholson, and Steve Hassler.

Management's Response: KC CARE Agrees Views of Responsible Officials and Corrective Action: This appears to be an isolated incident where the vendor was not entered at the correct time in our contract management database. But, in response to this incident, management created a clearer policy and outlined the timing of entering new vendors into the database and then making sure to do initial exclusion check during procurement process. Responsible Official: Dennis Dunmeyer, COO Anticipated Completion Date: Already implemented.

Action Taken in Response to Finding: A Subrecipient Monitoring Policy was implemented in May 2023 to establish processes for subrecipient identification, agreement requirements, invoice review, and ongoing monitoring. The policy was developed in alignment with guidance provided by the CDLE monitoring team. In subsequent years, the subrecipient monitoring framework was strengthened. As of February 2026, CLA’s grant management team has been engaged to further enhance subrecipient monitoring processes. Enhancements include: • Formalization and expansion of the Subrecipient Monitoring Policy, incorporated into the Financial Policies and Procedures, adopted May 2026 • Implementation of a standardized risk assessment process to evaluate subrecipient risk prior to award issuance • Implementation of a formal Subrecipient Monitoring Memorandum process to document monitoring activities • Implementation of a standardized monthly monitoring checklist to ensure consistent financial and compliance review (effective October 2025) • Establishment of a secondary review control requiring validation by the Chief Operating Officer or Chief Executive Officer in addition to the initial review by the Director of Finance & Operations (effective June 2026) These enhancements strengthened documentation, consistency, and oversight, and established a structured and audit-ready subrecipient monitoring framework. Control Enhancement: ActivateWork has strengthened its subrecipient monitoring practices through the implementation of a structured and documented framework that includes: A segregation of duties has been implemented within the monitoring framework, requiring preparer-level review by the Director of Finance & Operations and secondary review by executive leadership (Chief Operating Officer or Chief Executive Officer). These controls are integrated into ongoing financial operations to ensure subrecipient monitoring is consistently applied, documented, and reviewed. 1. Subaward Identification & FSRS Reporting Subawards are identified and tracked within the Subrecipient Determination Checklist. First-tier subaward reporting is completed in accordance with federal requirements. The Director of Finance & Operations is responsible for ensuring FSRS reporting is completed timely and accurately in accordance with federal deadlines, and documentation of submission is retained within the subrecipient file. 2. Suspension and Debarment (SAM.gov) Subrecipients are verified against SAM.gov prior to contract execution. Documentation of verification is retained in subrecipient files and is included as part of the Subrecipient Determination Checklist. 3. Risk Assessment (Pre-Award) A formal risk assessment is conducted prior to issuing subawards using a standardized scoring methodology that evaluates: • Experience with grants • Program complexity • Funding size • Documentation quality • Prior monitoring issues This assessment is documented within the Subrecipient Determination Checklist. 4. Ongoing Financial Monitoring Monthly invoice reviews are conducted, including: • Mathematical accuracy • Alignment with contract terms • Allowability, allocability, and reasonableness under 2 CFR Part 200 • Reconciliation to supporting documentation This is documented and maintained in the Subrecipient Monthly Monitoring Checklist. 5. Programmatic Monitoring Ongoing coordination is conducted between ActivateWork and subrecipient program staff to monitor: • Program delivery • Participant outcomes • Alignment with grant deliverables 6. Subrecipient Audit Review Subrecipient audit information is obtained and reviewed when applicable. The Director of Finance & Operations is responsible for review, and documentation is maintained within the Subrecipient Monthly Monitoring Checklist. 7. Subaward Agreement Requirements Subaward agreements include required federal award information, compliance expectations, and reporting requirements. The Director of Finance & Operations utilizes a subrecipient agreement template provided by the CDLE monitoring office and ensures all federal award information is complete. 8. Personnel Cost Monitoring (Payroll / Fringe) Personnel costs are reviewed based on documentation provided and evaluated for: • Alignment with program delivery • Reasonableness of allocations • Consistency with invoice detail Review is performed by the Director of Finance & Operations, with documentation maintained within the Subrecipient Monthly Monitoring Checklist. Monitoring & Review: • Monthly monitoring is conducted using a standardized checklist • All invoices are reviewed prior to approval and payment • Issues are documented and tracked through resolution Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate that subrecipient monitoring controls are operating effectively • Monitoring documentation will be reviewed for completeness and compliance Documentation & Evidence: • Monitoring memorandums maintained for each subrecipient • Monthly monitoring checklists retained • Supporting documentation maintained in Teams / SharePoint Control Owner(s): • Director of Finance & Operations • Finance Team • Program Leadership Responsible Party: Director of Finance & Operations, with executive oversight by the Chief Executive Officer Anticipated Completion Date: All corrective actions will be implemented as of June 30, 2026. Ongoing monitoring, documentation, and quarterly validation will continue as part of standard operations. Status: • Subrecipient monitoring policy: Adopted May 2023 and updated annually • Monitoring documentation (memorandum and checklist): Implemented in 2024 and enhanced in Oct 2025 • Policy strengthened: May 2026 to incorporate enhanced documentation, standardized procedures, and secondary review controls • Quarterly internal reviews will be conducted to validate the subrecipient monitoring controls are operating effectively: Jun 2026

Management Response: Management concurs with the finding. During the audit period, procurement documentation was not consistently maintained in a centralized manner sufficient to demonstrate full compliance with Uniform Guidance procurement requirements, although management believes procurement decisions were generally made in the best interests of the Organization. Since FY2023, SWIWC has significantly enhanced its procurement practices by implementing updated procurement policies aligned with Uniform Guidance, standardized procurement checklists, documented quote requirements, vendor selection documentation, SAM.gov verification procedures, approval workflows, and centralized procurement files. Staff have also received additional training regarding procurement documentation and federal compliance requirements. Management believes these corrective actions establish a substantially stronger procurement control environment and will support continued compliance with federal procurement standards. Anticipated Completion Date: Implemented 6/30/2026; ongoing monitoring. Responsible Party: Chief Financial Officer and Director of Finance, with applicable Program Managers responsible for providing programmatic documentation.

Condition: Controls were not sufficient to ensure that management has written policies and procedures surrounding procurement that align with Federal Procurement Standards outlined within the Uniform Guidance. Further, controls were not adequate to ensure that the history of procurement decisions was documented. Additionally, controls were not sufficient to ensure checks for suspension and debarment were performed and documented before entering into a covered transaction with third parties. Planned Corrective Action: The Organization will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2024

2023-011-Suspension and Debarment support Suggested Action: Enhanced our customer and subcontractor reviews to ensure we retain documentation demonstrating that IFDC does not do business with suspended and debarred contractors. Responsible Official: Vice President of Business Development Completion Date: 4/30/2026

Procurement Name of the Contact Person Responsible for the Corrective Action Plan: Amy Orebaugh, Finance Director. Corrective Action Plan: The City of Cedartown will update our procurement policies and internal control procedures to enforce documentation requirements. Anticipated Completion Date: December 31, 2026 2023-004 Year-End Financial Close and Reporting Controls 85

Personnel Responsible for Corrective Action: Vonda Floyd, Finance Director Anticipated Completion Date: September 30, 2026 Corrective Action Plan: Management will incorporate controls surrounding suspension and debarment to ensure the appropriate checks are performed prior to entering into covered transactions. Continuing education with Department Heads and staff surrounding suspension and debarment needs and best practices going forward.

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when racticable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Ida R. Kilcullen Director Bureau of Curriculum & Instruction Ministry of Education Contact: 680-488-2547 Email: ikilcullen@palauschools.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Finding No.: 2023-003 Area: Procurement, Suspension and Debarment Views of responsible official and planned corrective actions: The Trust has developed and implemented a due diligence checklist that includes procedures to verify that vendors, contractors, and sub-grantees are not debarred or suspended. This checklist has been incorporated into the Trust’s grant management and procurement processes to strengthen internal controls. By applying this process consistently, Trust ensures that all partners meet eligibility requirements and supports ongoing compliance with applicable federal regulations and grantor expectations. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started working on the checklist last year and finalized it in Q4 2025.

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.

Corrective Action: Request proof of contractor not being on the suspension or debarment listing from Engineering Firm. This finding was due to funds being transferred to a project that became a federal project once utilized. Stillwater County is careful when selecting contractors and as part of the bidding process assures that the contractors are in good standing. Additional vetting was needed when the funds were transferred to the project and the County was unaware of this requirement.

The City of North Bend acknowledges that a contract utilizing SLFR funds, and awarded to a software vendor, did not include within the contract, a required self-attestation concerning Suspensions and Debarment. The self-attestation was used in lieu of a documented review of the SAM.gov portal for suspensions and debarment. This was an oversight of the contract review process. Other contracts issued during the same period included self-attestation language from 2 CFR 200.317 through 2 CFR 200.327. In 2024 and 2025, the Public Works Deputy Director, Contract Specialist, and Capital Staff Accountant ensure adherence to all applicable local, State, and federal procurement laws and regulations as provided in the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibiting recipients from entering into contracts with suspended or debarred parties. The City of North Bend understands the significance of the finding and immediately took steps to review all subsequent contracts for compliance.

The following is Management’s Response to the Findings Required to be Reported by the Uniform Guidance. This document was prepared by management of the Catholic Charities of the Archdiocese of Oklahoma City (“CCAOKC”). 2023-002 Assistance Listing Number 93.576, Refugee and Entrant Assistance Discretionary Grants, U.S. Department of Health and Human Services, FAIN 90RP0121, Award Year 2023, Passed Through by the United States Conference of Catholic Bishops Criteria or Specific Requirement – Procurement, Suspension, and Debarment – 2 CFR § 200.317–.327; 2 CFR § 200.214 Finding Summary CCAOKC’s procurement documentation procedures were not adequate to meet the requirements of 2 CFR § 200.317–.327; 2 CFR § 200.214 - Procurement, Suspension, and Debarment. Explanation of Agreement/Disagreement: Management concurs with the findings and has updated CCAOKC’s procurement policy. Officials Responsible for Ensuring Corrective Action: David Ashton, Sr Director of Administration; E-mail – dashton@ccaokc.org Alan Lipps, Chief Financial Officer; E-mail – alipps@ccaokc.org Planned Completion for Corrective Action: Corrective action completed in FY 2026 Action in response to finding: Purchasing staff are trained in federal procurement requirements and were provided with a copy of the new policy.

Conditions 1-2: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 3: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 4: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.