Corrective Action Plans

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 disbarred and such procedure will be documented.

Personnel Responsible for Corrective Action: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City, Kansas Anticipated Completion Date: November 1, 2025 Views of Responsible Officials and Planned Corrective Action: The debarment check was not done with an updated contract for 2024. The 2025 contract renewal and debarment check are being finalized now. Purchasing reviews suspension/debarment checks for procurement over $50,000, but since this was a community partner agreement it was done separately from that process. Departments have now been trained this is required for contracts acquired through purchasing as well as partner agreements.

Isler recommended LCOG establish and implement formal, documented procedures for verifying that vendors are not suspended or debarred before entering into covered transactions paid with federal funds. These procedures should specify the method of verification (e.g., checking SAM.gov) and require retention of evidence (e.g., dated printouts or screenshots of the search results) within the procurement or vendor files. This has already been implemented as part of the procurement process.

The County will re-evaluate the design of internal controls over suspension and debarment to be in compliance with the Federal requirements and the County's procurement policy/procedures.

Auditor’s Recommendation: “We recommend management review all contracts with vendors and review the procurement policy to ensure compliance with the procurement and suspension and debarment standards within their policy and the Uniform Guidance.” Management response: The Family Place has reviewed its procurement and suspension/debarment procedures and concurs with the finding. During the period covered by the audit, staffing turnover and performance issues within departments responsible for procurement and grant compliance contributed to inconsistent application of policies and incomplete documentation. Since that time, The Family Place has replaced staff where needed due to performance problems and initiated training to ensure compliance and consistency with existing procurement policy for all organizational expenses of $10,000 or more. Corrective actions: The Executive Leadership Team has reviewed procurement responsibilities and clarified the roles of staff who approve or execute purchases and contracts. Hiring, training, and coaching were prioritized in early 2025 to address the identified deficiencies, and staff replacements have already been completed where necessary. Going forward: All staff responsible for procurement or contract approval will complete training on the Uniform Guidance procurement and suspension/debarment standards, including requirements for organizational purchases of $10,000 or more. Finance staff will review procurement documentation, vendor suspension/debarment verification, and contract approvals prior to payment to ensure full compliance with policy and federal regulations. These processes will receive additional oversight by the Chief Executive Officer, with assistance from the newly established Compliance Department, and the Board of Trustees. Responsible parties for corrective actions: The Chief Financial Officer will have direct responsibility for finance review of procurement documentation and vendor status verification prior to payment. The Chief Operations Officer will ensure that all required procurement and suspension/debarment checks are performed and documented. The Chief Executive Officer, Tiffany A. Tate, with assistance from the newly established Compliance Department, will confirm that compliance occurs on a timely basis. Separately, the Chief Financial Officer will report on progress to the Audit & Finance Committee of the Board of Trustees. Anticipated completion date: Refresher training of relevant staff and implementation of the strengthened procurement and suspension/debarment procedures has already been completed. Going forward, quarterly training will take place for team members directly involved in the procurement process.

2024-005 - Procurement, Suspension and Debarment Auditor Description of Condition and Effect: During Procurement, Suspension and Debarment testing, the Organization could not provide evidence that they determined whether vendors are 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 adhere to the policy over suspension and debarment review to ensure they are contracting with vendors that are allowable. Corrective Action: While the Organization has controls in place to ensure vendors are not suspended or debarred, management will ensure to have this process documented going forward. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025

Views of Responsible Officials and Planned Corrective Action Management agrees with the recommendation. To address this significant deficiency, Quivira Coalition will:

CORRECTIVE ACTION PLAN September 25, 2025 Cognizant or Oversight Agency for Audit The Center for Independent Documentary, Inc. (the Center) respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: January 1, 2024 – December 31, 2024 The finding from the December 31, 2024 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Procurement Policy Recommendation: We recommend that management establish a formal procurement consistent with the procurement standards set forth in the Uniform Guidance (2 CFR 200.317–327) issued by the U.S. Office of Management and Budget (OMB). Action Taken: We will work with the Board of Directors to establish a formal procurement policy that will include the following: • We will formalize procedures to confirm vendor eligibility, including consistent use of the SAM.gov exclusions list prior to entering contracts, and ensure documentation is retained for audit purposes. • The updated policy will outline specific steps for procurement activities at various thresholds, particularly mid-range purchases, with requirements for obtaining multiple quotes and documenting price comparisons. • In alignment with Federal guidelines, the revised policy will include a provision supporting preference for U.S.-made products and materials when feasible. • New sections will be added to address how the Center will manage vendor selection reviews, disputes, and issue resolution to promote fairness and consistency in the procurement process. • To ensure transparency and version control, the policy will include the date of each revision and a process for periodic review. The Center’s Management will implement the updated policy, coordinate training for programmatic staff, and monitor compliance with the updated procedures. We expect the revised procurement policy to be finalized and implemented by December 15, 2025. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call Susan Walsh, at 339-364-1277. Sincerely yours, Susan Walsh Executive Director

Finding number 2024-003, significant deficiency in internal controls over compliance – procurement. Recommendation: We recommend that the Organization implement one of the following procedures to verify and document that vendors are not on the suspended or debarred list: 1) checking the System for Award Management (SAM) Exclusions and maintain a printout of that as documentation of the check; 2) collecting a separately executive certification from the entity; or 3) adding a clause to the consulting agreement with the vendor. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action planned in response to the finding: While KRJC actually completed all debarment checks prior to funding any sub-awardees, this was done without documenting these checks for the organization’s files. In the past this was done by checking the System of Award Management. However, these searches were not documented in the consultant files. While KRJC will continue to conduct screenings on SAM, as of September 20, 2025, KRJC has adopted a new policy, where all sub-awardees, are required, as an element of their consulting agreement, to certify that they have been neither debarred nor suspended. Note: Several of KRJC’s sub-awardees in place as of December 31, 2024, were operating under existing contracts. For these sub-awardees, KRJC has required the sub-awardee to submit a separate document certifying that they have been neither debarred nor suspended. Planned completion date for corrective action plan: September 30, 2025.

Management Response #2024-003: Previously, the Corporation faced challenges in effectively monitoring and documenting grant activity due to limited formal processes. Documentation of policies and procedures was insufficient, and supporting materials were not stored in a centralized location, making information retrieval difficult. Since then, processes have improved, with enhanced documentation practices and better organization of grant-related records to support more efficient oversight and compliance. Corrective Action Plan: The Corporation has implemented the following corrective measures: • The Corporation established comprehensive, formal policies and procedures that document the current compliance practices. These procedures have been disseminated across the organization and incorporated into training programs to ensure all employees are aligned with the updated standards. • A procedure enhancement has been implemented in the procurement process, which requires the procurement manager to obtain three bids prior to the creation of certain purchase orders. This ensures competitive bidding and transparency in vendor selection. • Once a vendor is selected, the procurement manager will forward the vendor’s details to the compliance department. The compliance team will then verify the vendor's debarment status and federal eligibility to ensure compliance with all regulatory requirements. • A central repository platform has been created to store all vendor bids, price analyses, and related procurement documentation. This ensures that all relevant information is easily accessible and properly organized. • All accounts payable invoices designated for grant funding are now routed for prior approval to the respective grant program manager via the WorkPlace software before any payments are processed. This ensures proper oversight and alignment with grant requirements. These corrective actions aim to strengthen compliance, improve document management, and streamline oversight processes to prevent future issues related to grant monitoring and procurement. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO

In the summer of 2024, the Organization adopted a procurement policy compliant with the Code of Federal Regulations 2 CFR 200.214. The policy was formalized, announced, and implemented with the entire Organization's staff. At this time, all current contractors of federal grants were reviewed for eligibility by reviewing them against the debarred, suspended and otherwise excluded list. Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined procedures around all contractors ensuring appropriate selection processes and contractual terms. Anticipated completion date: March 31, 2025

Finding 2024-004 – Suspension and debarment compliance was not verified for five vendors. Corrective Action Planned: The Town of Clinton has verified that vendors listed in the period ending March 31, 2024 expenditure report were not on the Federal suspension or debarment list. The Town will review all applicable vendors for suspension and debarment compliance in the future. Completion Date: September 29, 2025 Contact: Michael J. Ward, Town Administrator

2024-001: Significant Deficiency in Internal Controls and Compliance Finding -Child Nutrition Cluster ALN (10.553, 10.555,10.559): A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food product. (Questioned Costs: None) The Town of Clinton/School Department will maintain proper procurement procedures in compliance with Local, State and Federal laws and regulations. When there are exemptions from state procurement laws, or when federal regulations are stricter the district will use the strictest rules, under 2 CFR 200.318-327. These procedures are included in the Financial Procedures Manual (pages 231-240, under Section II Procurement System). The Town of Clinton/School Department will obtain individual contract with vendors competitively procured by French River Collaborative, of which the district is a member. Key Control Key Actions Resources Needed Timeline Outcome Competitive Procurement Process Use appropriate resources to mitigate any errors or omissions, and maintenance of records accurately Individual Contracts, including suspension/debarment clause Cooperative Purchasing Sheets Internal Controls Guide Online Resources: Sams.gov FY24, FY25 ongoing Streamlined procurement process & internal controls for ALL funding sources Contacts: Food Services Manager & School Business Manager Submitted by Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

Recommendation: We recommend that the City review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Initially, the city was documenting the work performed on suspension and debarment through the creation of a list. In September 2024, the auditor's recommendation was to snip the search and note the search date. The city initiated this process immediately after the finding. Unfortunately, the test sample selected for the audit work was for purchases made in early 2024, before the new method was implemented. We have provided documentation of the new process and will continue to use it in the future. Name(s) of the contact person( responsible for corrective action: Maryanne Groat Planned completion date for corrective action plan: 9/30/2025 If the U.S. Department of the Treasury has questions regarding this plan, please call Maryanne Groat, Finance Director, at 715-261-6645.

FINDING 2024-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: To prevent future mishaps, the Grant Assistant will email department heads educating them on the procedures and expectations for suspension and debarment assessment. The email will be a step-by-step process for those responsible for checking suspension and debarment. This will prevent subrecipients from being missed. She will also check for suspension/debarment for each contractor/subrecipient through the County within a month of receiving a signed contract. This will ensure all contracts with the County are complying. Anticipated Completion Date: The Grant Assistant will begin this corrective action plan on October 1st, 2025.

Finding 2024-001: Suspension and Disbarment Condition: The Organization did not research all vendors for potential suspension or disbarment, and documentation of this research was not maintained. Corrective Action: Management’s understanding of the regulations is that only purchases from vendors equal to or greater than $25,000 must be researched for potential suspension or disbarment. Management will implement a policy that any subcontracts or purchases expected or known to be equal to or greater than $25,000 will be checked against SAM.gov for potential suspension or disbarment. Documentation of the research, such as a screenshot, will be maintained. Responsible Party: Program/Fiscal Director

FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Material Weakness in Internal Control Over Compliance – Suspension and Debarment ● Other Matter Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL guidelines and ensure a control is in place for verifying vendors are not suspended, debarred, or otherwise excluded per UG guidelines prior to use of the vendor. The Organization should ensure these policies are followed for all applicable vendors and that documentation related to these controls are maintained and documented. Views of Responsible Officials: Management agrees with the audit finding. Effective immediately, the Organization will update the Procurement and Vendor Management Policy to explicitly require suspension and debarment checks for all applicable vendors in accordance with 2 CFR 200.214 and 2 CFR Part 180. The Organization is implementing a standardized vendor verification form and will require procurement staff to document SAM.gov checks prior to contracting with any vendor. In addition, all staff involved in procurement will be trained on the updated requirements and documentation procedures. The CEO will perform quarterly monitoring to ensure compliance with federal procurement standards and internal policy. These corrective actions will strengthen internal controls and ensure compliance with federal regulations. Contact information for this finding: If the U.S. Department of Labor has questions regarding this schedule, please call Brandi Janke at (816) 520-4404. Completion Date: September 2025

Finding 2024-002 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Cindy Poore Contact Phone Number and Email Address: 317-733-2809, cpoore@zionsville-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Town will begin checking the EPLS system for all vendors receiving federal dollars. This will be part of the new purchasing policy that is being created for the Town. The Finance and Records Dept. will work with the Department Head receiving federal dollars to check the chosen vendor’s suspension and debarment status prior to proceeding with the project. Documentation verifying the check will be saved for audit purposes. Anticipated Completion Date: We will immediately begin checking the EPLS system for vendors receiving federal dollars. The new purchasing policy should be completed by September 2025.

Views of Responsible Officials and Planned Corrective Actions: Management agrees in review of this finding and going forward, Federal independent contractor agreement for Federal awards includes the following clause Re. Debarment and Suspension: Debarment and Suspension (Executive Orders 12549 and 12689). A contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. The Contractor represents that neither it, nor any of its principals or senior managers, are currently suspended or debarred or otherwise ineligible for award of a grant, contract, or cooperative agreement from the federal government, nor have they been proposed for suspension or debarment. Contractor agrees to notify Recipient immediately if at any point during the performance of work under this Agreement, it is proposed for suspension or debarment by any federal agency. The Excluded Parties List System has recently been consolidated within the System for Award Management at https://www.sam.gov/portal/public/SAM/. In additional action, management has updated its contract and procurement review procedures to include staff certifying selected vendors are not on the SAM.gov excluded parties list. Staff must also provide Finance a screenshot as backup. This item is listed on the Procurement Form as described under the Planned Corrective Actions on finding 2024-001.

FINDING 2024-002 Finding Subject: COVID-19-Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Material weakness, Modified Opinion Due to the U.S. Department of the Treasury's (Treasury) determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Covered transactions in the amount of $1,236,661 were made during the audit period to three vendors. Of the three vendors used by the County, one vendor contract had included a suspension and debarment clause. For the remaining vendors, the County did not check the ELPS, nor was a certification collected from the vendors, and a clause did not exist in the agreements with the vendors. Although the County had a policy to include a clause in vendor contracts related to covered transactions, no documentation to verify the County's compliance with the suspension and debarment federal requirement was provided for audit. For the two vendors, the County provided Suspension and Debarment Certifications dated 7-14- 25 and 7-17-25. Contact Person Responsible for Corrective Action: Britt Ostler Contact Phone Number and Email Address: 765-659-6330/bostler@clintoncountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County had their county attorney draw up the Suspension and Debarment Certificate and the Commissioner Assistant presents it when the Commissioner’s hire Contractors for County projects using federal money. It’s now in our office procedures to have the Suspension and Debarment Certificate ready for signature if a grant is using federal monies. It’s also recommended that all officeholders alert the Auditor and Commissioner’s Assistant if the grant is federal. The Auditor is sending an email reminding elected officials and department heads to communicate with the Commissioner’s office as to their federal grants. Contractors will need to sign the clause before they are permitted to start the project. This is more of a communication issue we need to resolve. The two vendors in question did comply and sign the Suspension and Debarment Clause before their checks were picked up. Anticipated Completion Date: July 28, 2025

Corrective Action Plan. Montour County respectfully submits the following corrective action plan for the year ended December 31, 2024. The findings from the Single Audit Report Year Ended December 31, 2024 included in the schedule of findings and questioned costs are discussed below. Finding 2024-001: Procurement, Suspension, and Debarment Epidemiology and Lab Capacity - (ELC) 93.323. Contact Person: Holly Brandon, Chief Clerk. Recommendation: The County 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: Montour County will update contract language requiring vendors to attest that they are not debarred or suspended, with the inclusion of language that allows for termination of the contract should a vendor's debarment status change. Project managers will be required to utilize SAM.gov to perform a debarment check on vendors. Date for Completion: 2/25/2025.

Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-002 – Procurement and Suspension and Debarment Description of Finding: BCHN did not perform a check at the System for Award Management Exclusions (sam.gov) to verify whether an employee or a vendor had been suspended or debarred before being hired. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN will engage an outside vendor to aid in the review of vendors and employees that are excluded or debarred. The outside vendor will check for exclusion or debarment monthly and provide BCHN with a report indicating that the check was done. The outside vendor will alert BCHN if any vendors or employees are flagged. This will help BCHN to ensure that this check is done timely. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the federal program: • One instance where the Cooperative followed a bid process, however, the documentation was not retained to support the selection. Additionally, the contract with the vendor was missing required contract provisions in accordance with Uniform Guidance. • Two instances where the Cooperative did not follow the procurement process as detailed in the procurement policy and did not have any formal documentation or contract in place with the vendor. • Three instances where the Cooperative entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Corrective Action Plan: We plan to review our procurement policy with all parties that may enter into contracts for the cooperative to be sure the policy reflects our needs and that procedures are being followed. We will also implement a review process where management signs off on bid selection documentation, including verification that vendors are not suspended or debarred. Responsible Individuals: Hollee McCormick, General Manager and Jason Troendle, Director of Operations and Engineering Anticipated Completion Date: November 2025