Corrective Action Plans

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION, GRANT No. AM-23-0295, YEAR ENDED JUNE 30, 2024 Name of contact person: Mayor and City Council Corrective Action: The city procurement policy will be updated to include references to all federal procurement standards and requirements. All directors and relevant individuals will be trained on the updated policies. Proposed Completion Date: December 31, 2025

2024-5 Suspension and Debarment Verification Recommendation: We recommend that the Borough establish and implement procedures to verify and document that all vendors and contractors receiving Federal funds are not suspended or debarred prior to entering into covered transactions. Acceptable procedures include checking vendor status on the SAM.gov website and printing or saving verification documentation, or obtaining vendor certifications confirming compliance. This review should be documented and retained for audit purposes. Management's Response: Management acknowledges that verification of vendor eligibility is an important control to ensure compliance with Federal requirements. The Borough will develop and implement procedures to verify and document the suspension and debarment status of all vendors and contractors receiving Federal funds. Going forward, management will perform and document a check of each applicable vendor on the SAM.gov website prior to entering into a contract or processing payment under a Federal program. Copies of the verification results will be retained as support.

Response acknowledges the material audit adjustment to the Organization’s financial statements. This situation is related to internal controls over compliance with suspension and debarment requirement. Management has improved procedures related to the future compliance with suspension and debarment processes for contracts. We also do not anticipate hiring any other contractors in the foreseeable future since our capital campaign building project is not completed.

Condition: Suspension and debarment compliance was not verified for four covered transactions. Corrective Action Planned: The Town will implement procedures to include a suspension and debarment certification in all federal contracts that are considered covered transactions to ensure that the contractors are eligible to receive federal funds and not excluded or disqualified from doing business. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawyer, Town Administrator

U.S DEPARTMENT OF TREASURY COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027, Grant Period - Year Ended December 31, 2024. Planned corrective Action: The District will review federal suspended and debarred listings prior to awarding any projects. Person Responsible: BCCD Manager Anticipated Completion Date: 11/12/2025

Views of Responsible Officials and Planned Corrective Actions: Management agrees documentation must be retained. Corrective Action: Management has implemented a formal process to document vendor eligibility verficiation. As of FY 2025, all vendors are revewied in SAM. gov prior to payment or contract execution, and a screenshot or PDF of the verification is saved to the Vendor Verification Log. The Grants & Finance Manager maintains this documentation as part of the procurement file.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Conservation District January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal reporting, suspension and debarment requirements. Name, address, and telephone of District contact person: Cori Turntine, Operations Manager 4422 E 8th Avenue, Spokane Valley, WA 99212 (509) 535-7274 Corrective action the auditee plans to take in response to the finding: We concur that the FFATA Subaward Reporting System (FSRS) reporting was not completed within the required timeframe. Upon identification of the reporting gap, the required subaward reporting was completed. We also concur that documentation was not retained for the suspension/debarment check for one contractor. The contractor was verified as not suspended or debarred; however, the documentation was not included in the project file. To strengthen internal controls and prevent future occurrences, the District is implementing the following corrective actions: • Policy & Procedure Updates: Updating federal grant management and procurement procedures to formalize FFATA reporting timelines, suspension/debarment documentation requirements, and staff responsibilities. • Centralized Tracking: Establishing a centralized tracking process for all applicable subawards, including FSRS reporting deadlines. • Documentation Standards: Requiring and documenting suspension/debarment checks at the time of procurement or subaward execution, consistent with 2 CFR 200.214 and related requirements. • Training: Incorporating suspension and debarment requirements into annual contract and procurement training. • Periodic Internal Review: Implementing internal reviews of a sample of federally funded contract files to verify that reporting and eligibility documentation are timely and complete. Anticipated date to complete the corrective action: The framework will be in place by December 31, 2025.

Force Detroit will monitor compliance through: ● Vendors/grantees must submit regular financial and programmatic reports, including expenditures, progress toward goals, and any issues encountered. ● Reports will be reviewed for accuracy, completeness, and alignment with the approved budget and program plan. ● Site visits to verify program activities, financial management practices, and overall compliance. Findings will be documented, and any deficiencies will trigger the Corrective Action Plan. ● Review of financial and programmatic documentation ● Verification of debarment and good standing with regulatory bodies ○ Vendors/grantees must provide confirmation that they are not debarred, suspended, or otherwise restricted from receiving federal funds.

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