Corrective Action Plans

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

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

Views of Responsible Officials and Planned Corrective Action: The District acknowledges the finding and agrees with the recommendation. To address this issue, the following corrective actions will be implemented: The Business Office will verify all vendors used in federally funded programs at least once annually and prior to disbursing funds o Persons responsible: Michele Hogan and April Young o Anticipated Completion Date: This process will be completed by June 12th, 2026 ● Staff will review both 2 CFR Section 200.214 and 2 CFR Part 180 for understanding and compliance o Persons responsible: Michele Hogan and John Lybert o Anticipated Completion Date: This will be completed by September 30, 2025

Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.

The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.

In response to the findings of the Annual Audit for Indiana Agriculture Education, Inc. dba Indiana Agriculture & Technology School, our business process includes a review on SAMS.GOV to ensure that payments from any federal grant are not made to any person or business entity that is listed as suspended, excluded or disbarred. The review of each payment is made prior to issuing an order for goods or services, by our corporate treasurer, currently Kendell Sanders, and is confirmed as approved for payment to our Executive Director prior to issuance of a voucher for payment and subsequent reimbursement with federal funds. This has been included in our internal financial procedures policy documents effective October 15th, 2015, by action of the Board of Directors. The policy shall be reviewed annually. Allan R. Sutherlin Board President Indiana Agriculture Education, Inc

2025-001 - Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through Al-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct Management's View and Corrective Action Plan The University concurs with this finding. On June 25, 2024, the University encountered multiple job failures due to the expiration of a Java Security Certificate. As a result, the file which was to be submitted to the University's third-party servicer for new vendor suspension and debarment screening was not transmitted. The University's Data Center has procedures in place which should have ensured that the vendor file was resubmitted to the third-party servicer once the University's server-related issues were resolved. Unfortunately, due to incorrect documentation in the production operations system (a.k.a. runbook) the vendor file was not resubmitted. Upon further review it was determined that over the course of the fiscal year this was the only incident where the file failed to be transmitted to the servicer. The 25 vendors not screened as a result of the job failure represented less than 1 % of the 3,860 new vendors successfully transmitted and screened by the third-party servicer during the 2025 fiscal year. To ensure that any system issues affecting the daily transmission of the vendor files to the third-party servicer are promptly resolved and new vendors are checked for suspension and debarment, the Information Technology team will enhance the procedure documentation (runbook) and team members will receive cross training. Both the update to the runbook and cross training of team members will be completed by the end of November 2025. University Contact Lyndsay King Associate Vice President, Finance and University Controller Office of the Controller 617-552-3363

2025-004 – Lack of Documentation for SAM.gov Exclusion Checks. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Village did not retain documentation to support that the exclusion checks were performed for vendors. As a result, there is no evidence that the Village verified whether these parties were suspended or debarred prior to entering covered transactions. Auditor Recommendation. We recommend that the Village retain evidence that SAM.gov exclusion checks are being completed for vendors to document that vendors are not suspended or debarred prior to entering covered transactions. Corrective Action. The Village will begin retaining documentation for its SAM.gov exclusion checks that it completes for vendors to verify whether these parties were suspended or debarred prior to entering covered transactions. Responsible Person. Ross Wilson, Village Clerk/Treasurer. Anticipated Completion Date: February 2026.

2025-005 Suspension and Debarment Corrective action planned: OMC currently has a policy and procedure for vendor exclusion checks prior to executing contracts. This finding appears to be an incidental omission that resulted in no excluded vendors being identified. In one case, the vendor was an existing one for many years. The CFO/Designee will monitor to assure exclusion checks prior to CEO signing any contracts or purchase orders with any vendor over $25,000 per year and will update policy as necessary in accordance with regulations. OMC will seek HRSA guidance on periodic review of existing vendors Anticipated completion date: September 30, 2025 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025. The SVP/CFO Mary Maziejka will be responsible for development and implementation of the policy.

Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award.Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization implemented internal controls over procurement and suspension and debarment compliance. Management will require documented verification of vendor eligibility through appropriate federal and state exclusion checks or signed certification, as applicable, before any procurement is finalized. All procurement-related documentation—including procurement method determinations, vendor selection support, debarment verification evidence, and required certifications—will be subject to supervisory review to ensure completeness and compliance with federal requirements. The Organization will retain all procurement and debarment documentation in the official procurement or contract file in accordance with federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2026.

Finding Number: 2024-008 Finding Title: Procurement and Debarment Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 21.027 • Federal Program Names: Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Procurement Standards (2 CFR §200.317-200.327); Suspension and Debarment (2 CFR §200.214) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its procurement responsibilities. The Organization is in process of implementing procedures to ensure the compliance with the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Procurement Suspension and Debarment Policy Development • Action: Develop and adopt written procurement policies that comply with the Uniform Guidance. Include specific requirements for reviewing procurement policies, suspension/debarment procedures, and other compliance areas. Board will formally approve policy by resolution. • Responsible Person/Title: Board President with Contract Accountant • Anticipated Completion Date: February 15, 2026 Corrective Action #2: Ongoing Monitoring Program • Action: Board will designate Board member or engage consultant to conduct reviews of vendors for procurement and suspension/debarment compliance. • Responsible Person/Title: Board-designated monitor • Anticipated Completion Date: February 15, 2026

Finding Number: 2024-003 Finding Title: Subrecipient Monitoring Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring (2 CFR §200.332(d)); Procurement Standards (2 CFR §200.317-200.327); Suspension and Debarment (2 CFR §200.214) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its responsibilities to monitor the subrecipient. The Organization is in process of implementing procedures to ensure the subrecipient complies with the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Subrecipient Monitoring Policy Development • Action: Develop and adopt written subrecipient monitoring policies and procedures complying with 2 CFR §200.332. Include specific requirements for reviewing procurement policies, suspension/debarment procedures, and other compliance areas. Define monitoring activities, frequency, and documentation requirements. Board will formally approve policy by resolution. • Responsible Person/Title: Board President with Contract Accountant • Anticipated Completion Date: February 15, 2026 Corrective Action #2: Pre-Award Risk Assessment Process • Action: Implement pre-award risk assessment for all subrecipients. Require subrecipients to provide documentation of procurement policies and debarment procedures prior to executing subaward agreements. Board Treasurer will review and approve subrecipient policies for Uniform Guidance compliance before subaward execution. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 (initial); Ongoing for new subawards Corrective Action #3: Ongoing Monitoring Program • Action: Board will designate Board member or engage consultant to conduct annual reviews of subrecipients verifying procurement and suspension/debarment compliance. Require subrecipients to submit documentation of debarment checks for all vendors. Review subrecipient procurement transactions on sample basis. Designated monitor will report findings to full Board quarterly. • Responsible Person/Title: Board-designated monitor • Anticipated Completion Date: March 31, 2026 (initial monitoring); Ongoing annually thereafter Corrective Action #4: Technical Assistance to Subrecipient • Action: Provide training and technical assistance to current subrecipient to develop compliant procurement policies and debarment procedures. Engage consultant if needed. Create guidance materials and templates. Schedule quarterly meetings between Board representative and subrecipient. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 Corrective Action #5: Monitoring Documentation System • Action: Maintain comprehensive monitoring files documenting all activities, findings, and corrective actions. Board President will report monitoring results to full Board quarterly. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 (system implementation); Ongoing

The City will ensure that all future contracts awarded under this program are in compliance and will have contractors sign to verify that they are in compliance.

Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town Administrator who serves as the Town’s Chief Procurement Officer will run the verification upon the approval of any agreement or contract with a vendor. The verification will then be run annually (end of December) for any vendors who still have open projects to be paid. The verification will be kept with the vendor and procurement file for reference if needed. Name(s) of the contact person(s) responsible for corrective action: Chad Lovett Town Administrator Planned completion date for corrective action plan: Completed December 30, 2025

Condition: Morton County did not have documented policies in place to verify that vendors receiving federal funds were not suspended or debarred from participation in federal programs. During the audit period, the County did not perform checks of the federal System for Award Management (SAM.gov) or obtain certifications from vendors to demonstrate compliance with federal suspension and debarment requirements. Management’s Response: We Agree. We will review our current procedures and policies and ensure policies in place include a review of vendors to ensure they are not suspended or debarred. Anticipated Completion Date: FY 2025

Finding 2024-005 – Inadequate Procurement Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the InteriorFederal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Federal procurement standards require non-Federal entities to maintain records sufficient to detail the history of procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. Competitive procurement must follow the entity’s written procedures consistent with 2 CFR §§200.317-200.327, including:  Written procedures for procurement (§200.318(a)).  Full and open competition requirements (§200.319).  Methods of procurement (sealed bids, proposal requirements, and required documentation (§200.320).  Contract cost and price justification, (§200.324).  Suspension/debarment verification for covered transactions (§200.214; §200.213). Condition: During the audit period, the Entity did not retain sufficient procurement documentation for several contracts funded under the above Assistance Listings. Specifically, files lacked one or more of the following:  Evidence of the procurement method used.  Price or cost analysis.  Suspension/debarment checks for vendors where required.  Documentation of competition.  Conflict-of-interest attestations. Cause: Partnership for the Umpqua Rivers procurement procedures were not sufficiently detailed or consistently applied to federal purchases. No evidence of procedures or review for procurement or suspension / debarment was provided to auditors. Turnover and limited training on Uniform Guidance procurement standards contributed to the inconsistent file completeness. Effect or Potential Effect: Without complete procurement documentation, the Entity cannot demonstrate compliance with federal procurement requirements, increasing the risk of:  Noncompetitive awards or unreasonable prices.  Unallowable costs for the award requirements.  Potential disallowance or repayment of federal funds.  Findings in federal or pass-through monitoring and future audits. Questioned Cost: Yes, $902,496 related to expenditures that had no procurement support or detail. Context: During our audit, it was found that the Partnership for the Umpqua Rivers had experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to procurement, suspension or debarment procedures or processes. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Update Written Procurement Procedures o Incorporate Uniform Guidance thresholds and methods (§200.320), competition requirements (§200.319), and documentation expectations (history of procurement). o Embed steps for suspension / debarment checks and Appendix II Contract clauses.  Standardized Procurement Checklist o Pre-award checklist that verifies: method, competition evidence, cost/price analysis, conflict of interest attestations, SAM exclusion check, and required federal clauses. o Post -award checklist ensuring complete contract file (award memo, bid tab / evaluation, signed agreement, clause verification).  Cost/Price Analysis Guidance o Require documented price reasonableness for small purchases, formal cost or price analysis for larger or sole-source awards, per (§200.324).  Training & Accountability o Provide targeted training to procurement and program staff on 2 CFR §§200.317- 20.327 and Assistance Listing award conditions. o Implement supervisory pre-award review and periodic file audits. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

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.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027; Passed through the Pennsylvania Department of State, Grant Period – Year Ended December 31, 2024. Recommendation: The District should apply the guidance in section 200.214 of the Uniform Guidance in determining whether parties are excluded or ineligible for participation in Federal programs. Views of Responsible Officials: Management agrees with finding. Planned Corrective Action: For all future federal awards, the District will complete a disbarment search through SAM.gov applying the guidance in section 200.214 of the Uniform Guidance in determining whether parties are excluded or ineligible for participation in Federal programs. Persons Responsible: Carrie Richmond, District Manager Anticipation Completion Date: Immediately

Views of Responsible Officials: 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. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timing, the earliest possible implementation of corrective action is in FY 26. 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.

Response to finding 2024-002 – Procurement, Suspension, and Debarment Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-002. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, this finding continued into the 2024 audit period. The Organization operated with significantly reduced staffing and limited capacity, which delayed the development of procurement policies addressing suspension and debarment requirements. Initial governance updates occurred during the 2025 Q4 Board meeting, where the Board approved a revised version of the By-Laws focused on correcting deficiencies in board structure and conflict-of-interest provisions. Procurement procedures recommended in this finding were not included in that initial revision but are scheduled for development and implementation as part of the 2026 rebuilding phase. Corrective Action taken in 2025: While no procurement-specific corrective action has yet been implemented, foundational updates to the By-Laws were approved at the 2025 Q4 Board meeting to address structural governance issues. These updates establish the basis for incorporating required procurement, suspension, and debarment procedures. The Operations Manager and Advisory Consultant have begun drafting updated procurement policies to ensure compliance with federal requirements. Corrective Action Planned for 2026: Draft procurement, suspension, and debarment policies will be completed and presented to the Board as a formal resolution in early 2026. Upon approval, these policies will be incorporated into the By-Laws and will take immediate effect. The Board has also approved the planned hiring of a consultant with Executive Director and strategy experience in 2026 to support policy implementation, training, staff alignment, and ongoing compliance review. These measures will ensure full compliance with procurement requirements throughout the 2026 operating year and beyond.

U.S. Department of Health and Human Services Material Weakness in Internal Controls over Compliance and Material Noncompliance: Procurement, Suspension and Debarment Recommendation: CLA recommends the Alliance to develop the procurement policy compliance in with Uniform Guidance, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Alliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HIV Alliance updated our Procurement Policy to comply with the federal guidance using the recommendation provided by CLA. The Board of Directors voted toapprove the updated Procurement Policy in June of 2025 and we implemented the updated policy on July 1, 2025. Name(s) of the contact person(s) responsible for corrective action: Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025