Corrective Action Plans

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained. Corrective Actions Taken or Planned MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions: Policy and Procedure Update As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file. Procurement Checklist Enhancement Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented. Training Implementation All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications. Ongoing Monitoring A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained. Contact Person Responsible Tariq Bahich Senior Director Finance Anticipated Completion Date Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.

Views of Responsible Officials: Management will develop a supplemental checklist of all regular and annual requirements related to subawards included in its compliance manual. Such a checklist will include the timely reporting of subawards in excess of $30,000 in the FSRS, annual suspension and debarment checks and risk assessments for new awards. This checklist will be completed annually.

Update the board approved NCM Financial Policies document to include an additional approval step for all federal award spending over $20,000 to ensure appropriate procurement approval policies are implemented. September 30, 2025. Kevin Cantfil, VP of Finance and Administration.

Contract for third party training for both programmatic staff responsible for administering federal award projects and the finance and administration staff responsible for contract review and making final payments. September 30, 2025. Kevin Cantfil, VP of Finance and Administration.

Corrective Action Plan for Annual Audit 2024 Finding One: 2024-001 Procurement, Suspension and Debarment Auditor’s Recommendations: Tacoma-Pierce County Chamber of Commerce should conduct research and keep records for procurements not secured using a competitive process. Corrective Action: TPCC Staff will continue to use a competitive procurement process for vendors when possible, per TPCC procurement policy. CEO, Andrea Reay, will amend the current procurement policy to include a process for when competitive procurement is not possible due to unique needs/benefits. This will include a process documenting research conducted that demonstrates the unique benefits to the program/participants for any vendor that is not secured using a competitive process. Documentation includes dates discussed, names of individuals involved in the discussion and decisions made. The debarment check with sam.gov will be included in the documentation packet. Timing of remediation completion: CEO, Andrea Reay, will complete by May 31, 2025.

Action taken: Management has updated the process to verify that subrecipients are not suspended or debarred from receiving federal funds. While management was previously reviewing and confirming eligibility, this confirmation was not consistently documented in the records. Effective immediately, management has implemented a new step requiring the inclusion of a physical screenshot from SAM.gov in the contractor records. This adjustment ensures proper documentation and alignment with compliance requirements. Person responsible: ShaQuina Davis, Chief Operating Officer Date completed: February 10, 2025

The SPS Federal Grants Manual has been updated to consider this recommendation and the federal suspension and debarment requirements.

Suspension and Debarment – Assistance Listing No. 21.027 Recommendation: We recommend the Organization revised its internal controls related to suspension and debarment such that they align with the requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has added a Procurement, Suspension and Debarment policy and will continue to verify contractors as required. The Organization will improve on documentation procedures for these verifications. Name of the contact person responsible for corrective action: Marlon Mitchell Planned completion date for corrective action plan: June 30, 2025

Finding 2024-010 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295-01-01 Year: 12/01/2022 – 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

Finding 2024-002 Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

FINDING NUMBER: 2024-001 Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment, and exclusion is conducted prior to entering a contract Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2025

Finding 2024-001 Federal Agency Name: U.S. Environmental Protection Agency / U.S. Department of Treasury Assistance Listing Number: 66.458 / 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds / Capitalization Grants for Clean Water State Revolving Funds Finding Summary: The City had performed suspension and debarment check prior to entering into the transaction; however, the documentation was not retained. Therefore, testing was unable to verify the debarment check had been performed. Corrective Action Plan: The city of Nampa asserts that the material finding from the single audit of Federal Awards greater than $750,000, relates to the “Debarment verification” requirement that is correctly being executed, but not documented. The lack of documentation forms the basis of the finding, and is applicable to the programs listed below: COVID-19 Coronavirus State and Local Fiscal Recovery Funds 21.027 Capitalization Grants for Clean Water State Revolving Funds 66.458 Additionally, this step will be added to the capital projects process review checklist as a required step in the project approval. Responsible Individuals: Clay Long, Director – Public Works Business Administration Chris Boaz, Grants and Capital Manager Anticipated Completion Date: February of 2025

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Corrective Action Plan: The Authority acknowledges the finding and is currently working to correct this. Responsible Official: Contact person is Todd Shurn, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2025

As stated by the auditor, SCEC is selective about who to enter contracts with and has long standing relationships with the organizations we were working with on these efforts, who also had other Federal contracts in process that we were aware of. We have instituted a finance procedure to check all contractors and sub-contractors on the Sam.gov’s verification of debarment and suspension tool before the first payment under the contract is issued and a policy that all SCEC contracts or subawards over $25,000 that utilize federal or state funds must include a suspension and debarment certification.

Special Education Cluster - Procurement, Suspension and Debarment The finding is a material weakness in internal control over federal awards and material compliance finding due to the District not obtaining and/or retaining documentation for an adequate number of price quotes and no retention of documentation related to suspension and debarment of vendors. The District will continue to train staff on the District’s procurement policy and the requirement to retain documentation for procurement decisions, including documentation of suspension and debarment verifications. Responsible official: Janice Boucher, Finance Manager, jboucher@shawanoschools.org Anticipated Completion Date: June 30, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Name of contact person: Peri Whiteclay Corrective Action: Checking the SAM system was added to the county’s grant management procedures after the audit of fiscal year 2023. Proposed Completion Date: Completed.

Finding 2024-005 Procurement Policy – Procurement, Suspension, Debarment Name of responsible official: Owen Astbury- Selectboard Chair Corrective action: Annually Anticipated completion date: June 30,2025

Federal Award Finding: 2024-002 Material Weakness in Compliance and Internal Control over Procurement and Suspension and Debarment Name and Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH has evaluated the processes and procedures regarding procurement and suspension and debarment, as well as the processes for maintaining records supporting all procurement activity. Management will appoint an individual to oversee this. Proposed Completion Date: June 30, 2025

2024-005 Program: Equitable Sharing Program Federal Financial Assistance Listing Number: 16.922 Federal Grantor: U.S. Department of Justice Award No. and Year: 2024 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department followed their internal control to ensure the vendor was not suspended or debarred prior to entering the transaction. Cause: The Sheriff department did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County’s policy was not consistently followed, which required verification of suspension or debarment prior to entering the contract. The department subsequently verified that the vendor was not suspended or debarred. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested. The condition noted above was identified during our procedures related to procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff’s Department adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Management Response and Corrective Action: 1. Person Responsible: Yvette Torres, Procurement Contract Manager, Senior 2. Corrective Action Plan: The Sheriff’s Department acknowledges the audit finding and is committed to implementing a robust due diligence process to ensure compliance with procurement and suspension/debarment regulations. The following corrective actions will be taken: a. Policy Reinforcement and SAM.gov Checks: The department will reinforce adherence to existing procurement procedures that require suspension or debarment verification prior to entering into any contract by requiring all procurement staff to verify vendor status on the System for Award Management (SAM.gov) before executing any contracts. Proof of verification including the applicable date printed will be retained and included in the contract file to ensure compliance with federal regulations and internal policies. Additionally, as an added layer to ensure compliance with all federal, state and local laws, the County Procurement Office has required that all Deputy Purchasing Agents (DPA’s) conduct a Due Diligence check on all County Contracts which includes a SAM.gov check. b. Refresher Training: All procurement staff will participate in refresher training to reinforce the importance of compliance with 2 CFR section 180.300. This training will cover proper procedures for conducting suspension and debarment checks using SAM.gov and emphasize the documentation requirements to maintain compliance. c. Enhanced Internal Controls and Monitoring A secondary review process will be implemented, requiring a supervisor or manager to verify the suspension or debarment check documentation prior to contract execution. Additionally, periodic internal audits will be conducted to ensure compliance with federal regulations and internal policies. Any identified discrepancies will be promptly addressed with corrective actions to maintain robust internal controls. 3. Anticipated Implementation Date: April 2025

2024-007 Program: Santa Ana River Mainstem Project Federal Financial Assistance Listing Number: 12.U01 Federal Grantor: U.S. Department of Defense Award No. and Year: 2020 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: During our testing of the Orange County Public Works’ (OCPW) compliance with procurement and suspension and debarment requirements, we noted for three (3) of three (3) contracts selected for testing, there was no evidence that the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County Policy. In addition, the following information was not provided at the time of the contract award for three (3) of three (3) contracts selected: •Byrd Anti-Lobbying Amendment •Debarment and Suspension Cause: The OCPW did not follow their policy to verify the information described in the condition prior to entering the transactions and did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The County’s control and compliance were not consistently followed, which required verification of suspension and debarment prior to entering the contract. Additionally, the OCPW department did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) of ten (10) procurement contracts were sampled. The condition noted above was identified during our procedures related to procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW department adhere to its procurement procedures requiring the suspension and debarment verification is performed prior to entering into a covered transaction. Additionally, we recommend the OCPW modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contracts in accordance with 2 CFR Appendix II to Part 200. Management Response and Corrective Action: 1. Person Responsible: Joe Sly 2. Corrective Action Plan: OCPW will send a memo to impacted vendors requesting a contract modification to include the federal requirement 3. Anticipated Implementation date: September 15, 2025

Action taken in response to finding: The Comptroller’s Office has reiterated procedures to departments to ensure they document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Stephen Curley, Comptroller. Planned completion date for corrective action plan: Completed. An email was sent out to all department heads to distribute and reaffirm with staff that they need to ensure all vendors paid from federal funding are not suspended or debarred from receiving federal funds which included procedures on how to confirm this.

Finding 2024-001: Suspension and Debarment Control Design Deficiency Grantor: Department of the Treasury Program Title: COVID-19 American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds Award Name: American Rescue Plan Act (“ARPA”) - Coronavirus State Fiscal Recovery Fund and Coronavirus Local Fiscal Recovery Fund, Coronavirus State and Local Fiscal Recovery Funds (HVIP) Award Numbers: GRT000755, GRT000759 Assistance Listing Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Years: May 1, 2023 – December 31, 2024, July 1, 2023 – September 30, 2024 Passthrough Entities: Baltimore City Health Department, Mayor and City Council of Baltimore Management agrees with the finding and recommendation. Management utilizes a vendor inventory system, Payment Works, for all new vendor set ups. Payment Works utilizes a sanctions list check, which is a third-party service that functions as an aggregator from multiple sources, including SAM.gov. Additionally, management performs an alternate procedure to manually check SAM.gov for vendors not set up in Payment Works. Management will continue to quarterly reconcile the federal grants vendor listing with Payment Works to ensure all necessary vendors are being reviewed for suspension and debarment prior to entering into covered transactions. Furthermore, management will collaborate with the procurement team to determine what revisions are necessary to our current grant accounting policy related to suspension and debarment in order to be in compliance with the Uniform Guidance requirements. Management has remediated this finding with the enhanced control process that started at the end of fiscal year 2024.

Finding 2024-715: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Requirements Planned Corrective Action The university will take a multi-step approach to correct this issue on campus. 1. Further research will take place to determine if the UW Madison procedures include the SAM.gov database. If the SAM.gov database is not used in the daily debarment review process, the university will work with the Supplier File team to have this added. 2. The Procurement & Strategic Sourcing department will develop a procedure to verify that any supplier listed on purchase requisitions using 144 funds is verified against the SAM.gov database. Anticipated Completion Date: 03/13/2026 Person responsible for corrective action: Cheri Falkner, Director Procurement & Strategic Sourcing Division of Finance & Administration falknecl@uwec.edu

Planned Corrective Action: The Wisconsin Department of Tourism (WDT) will review all applicable federal requirements for funds it administers to ensure it fully complies with federal requirements. As related to suspension and debarment requirements, WDT will add a clause to its contract template that is used for federal funds to require contractors to certify that they are not debarred or suspended. Anticipated Completion Date: June 1, 2025 Person responsible for correction action: Maria Van Hoorn, Deputy Secretary mvanhoorn@travelwisconsin.com

Planned Corrective Action: Universities of Wisconsin Administration (UWSA) has contracted with UW-Madison Research and Sponsored Programs (RSP), effective fiscal year 2025, to ensure UWSA does not enter into a subaward contract with a suspended or debarred party. Additionally, the UWSA Office of Finance, Procurement – Strategic Sourcing is investigating standard procurement contract revisions to include a clause in the standard contract template where the subrecipient provides an assurance that neither the subawardee nor any of its principals are debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in the federal project. Where a review of the suspended and debarred parties listing in SAM.gov is an appropriate additional step, documentation of that validation step will be maintained. Anticipated Completion Date: Corrective action to ensure UWSA does not enter into a subaward contract with a suspended or debarred party has been completed by contracting with UW-Madison, Research and Sponsored Programs. Investigation by UWSA Office of Finance, Procurement – Strategic Sourcing regarding standard procurement contract revisions to include a clause in the standard template where the subrecipient provides an assurance that neither the subawardee nor any of its principals are debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in the federal project will be completed by June 30, 2025. Person responsible for corrective action: Josh Smith Senior Associate Vice President for Finance Universities of Wisconsin josh.smith@wisconsin.edu