Corrective Action Plans

The Division will formalize and adopt a procurement policy. This will also include a suspension and debarment check of vendors. Anticipated Completion Date: 8/1/25. Responsible Contact Person: Yohannes Gedlu, NW Divisional Finance Director & Julie Luft, NW Social Services Director

Subject: 2024-002 Material Weakness – Procurement and Suspension and Debarment Noncompliance Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness – Procurement and Suspension and Debarment Noncompliance Recommendation: The auditor recommends the City develop and implement formal written procedures to ensure suspension and debarment checks are performed on all CSLFRF transactions and documented appropriately. Planned Corrective Action: The City agreed with the recommendation and plans to implement corrective action plan by December 31, 2025. Staff are in the process of drafting internal policies for adoption by the appropriate boards to address this item as soon as possible for any of our grant funds not managed by a third-party administrator.

The Town is now duly aware of its responsibilities pertaining to this program and will comply with the program requirements for suspension and debarment including evaluation and documentation for program expenditures.

CORRECTIVE ACTION PLAN Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in Monroe Community Mental Health Authority’s (MCMHA) Single Audit report for the year ended September 30, 2024, and corrective actions to be completed. Finding: 2024-001 – Procurement, Suspension and Debarment Auditor Description of Condition and Effect: The CMHSP did not document the noncompetitive procurement process pursuant to 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Auditor Recommendation: That the CMHSP review/update policies and procedures to ensure that formal procurement methods are documented, and verification of suspension, debarment, or exclusion is conducted prior to entering into a contract. Corrective Action: Management acknowledges the situation and is developing process and procedure to correct this going forward. Responsible People: Chief Financial Officer and Chief Operating Officer. Anticipated Completion Date: September 30, 2025

Recommendation – We recommend the Association implement a formal policy and procedure to verify all vendors against SAM.gov for covered transactions exceeding $25,000. Staff responsible for federal procurement should be trained, and documentation of vendor status verification should be retained with procurement records. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.

Finding Reference Number: 2024-008 – COVID-19 - Coronavirus State and Local Recovery Funds. Compliance Requirement: Internal Control noncompliance - Procurement, Suspension, and Debarment. Name of Contact Person: Jim Conklin. Views of Responsible Officials: Management acknowledges the finding and understands the need to perform a review of vendors paid using federal grant funds to determine if they are suspended or debarred. Planned Corrective Action: The Organization will provide training to staff involved in procurement to search the federal government website to determine if vendors selected are suspended or debarred. Documentation of this determination will be retained and reviewed by a member of management to evidence internal control over this procedure. Anticipated Completion Date: 6/30/2025.

Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements. The Problem: During testing the auditors noted that one instance of purchasing using WSDA funds was made without WSDA prior approval and proper documentation of suspension and debarment or WSDA prior approval. Established Standard: Organization must verify SAM registration and conduct suspension, and debarment checks prior to entering into any sub-agency agreement, contract, purchase, or equipment repair over $5,000. It is recommended that lead agency verifies, at least annually, that sub agencies and vendors are not suspended or debarred. Information about suspension and debarment checks is to be entered onto a spreadsheet of approved vendors. When the lead agency enters into a covered transaction with another agency or vendor, lead agency must verify that the entity with whom business is transacted is registered with SAM and is not excluded or disqualified. There are two methods for verification: A. Checking SAM.GOV exclusions (this method requires saving a copy of the verification search) B. Collecting a signed certification from the vendor. Actions to be taken: • Updated training of TCFB staff on the Policy/Procedures for procurements using WSDA funding. • Create step-by-step instructions for purchases using WSDA funding. • Effective October 1, 2024 WSDA’s threshold for preapprovals changed to $10,000. We will update our purchasing policy to reflect this change. Action Assignments: • Instruction checklist will be created by lead purchaser. • Lead purchaser will ensure that any purchases follow the Policy/Procedures for procurement. • Lead purchaser will be responsible for documenting SAM registration, Suspension and Debarment check, and WSDA pre-approvals. The documentation will consist of a copy of the exclusions page on SAM.GOV, as well as a spreadsheet of approved vendors with a date of last check. Timeline: • Instruction checklist for purchases using WSDA funds will be created by July 1st, 2025. • A spreadsheet has already been created to capture the information concerning Suspension and Debarment checks. A separate folder contains copies of each entities exclusion page from SAM.GOV. Verify Implementation: • In July 2025 Lead Purchaser will submit to the Executive Director: A. A copy of step-by-step instruction checklist. B. A copy of the spreadsheet with Suspension and Debarment checks C. Copies of exclusion pages from SAM.GOV Finance Dept. will verify invoice have received WSDA prior Approvals

Condition: The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Planned Corrective Action: 1. Policy Update: The Town will verify that its procurement policies and procedures to explicitly require verification of all vendors and subrecipients against the System for Award Management (SAM) at https://sam.gov prior to award of any federal contract or subaward is being followed. 2. Training: Staff responsible for procurement and grant administration will be trained on: The requirements of 2 CFR 200.214 and 2 CFR Part 180. How to use SAM.gov to verify suspension and debarment status. 3. Documentation Procedures: The Finance Department will implement a checklist that includes required documentation of SAM verification for every covered transaction using federal funds. 4. Monitoring and Review: The Grants Administrator will conduct periodic reviews of federal purchases to ensure compliance with suspension and debarment requirements. Contact person responsible for corrective action: Chris Fiandaca, Finance Director – Town of Parker Anticipated Completion Date: August 1, 2025

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