Corrective Action Plans

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Name of contact person: County Commissioners Corrective Action: Roosevelt County will follow the procedure of verifying contractors through SAM or GSA Websites when using SLFRF funds. Proposed Completion Date: Immediately.

Condition: We noted during testing that the City did not maintain sufficient documentation to ensure that subrecipients and contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into a contract or agreement with the third party. Planned Corrective Action: The City of Port Huron will implement a new process for approval of all invoices related to ARPA grant expenses. This includes a check for suspension and debarment prior to any invoices approval and appropriate documentation. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: December 31, 2024.

Finding Number: 2024-002 Condition: The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Planned Corrective Action: SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment. Contact person responsible for corrective action: Ryan Byrne, VP of Finance and CFO Anticipated Completion Date: 12/31/2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No. Direct allocation and AM-23-0287 Name of contact person: Kelly Strecker Corrective Action: The City commits to ensuring that a procurement policy be put in place that will allow it to comply with procurement standards outlined in the Uniform Guidance. Proposed Completion Date: Immediately

MATERIAL WEAKNESS 2024-003 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Suspension and Debarment Recommendation: We recommend that the Organization establish and maintain effective internal controls over suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One City Schools adopted a procurement policy in November 2023 with a $150,000 threshold for suspension and debarment. With the development of the Federal Funds Procedural Manual, that policy will be amended to the $25,000 threshold identified by the grant guidance. The procedural manual also stipulates a suspension and debarment process that adheres to grant guidance. Name(s) of the contact person(s) responsible for corrective action: Janel Vertz, Finance Director Planned completion date for corrective action plan: January 2025

Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Finding Summary: As a result of our test work, we noted three (3) out of three (3) instances where there was no evidence that the District verified the subrecipient entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Repeat Finding from Prior Years: No Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District will develop procedures outlining the requirement to 1) access the System for Award Management (SAM) exclusion list, 2) collect a certificate from the subrecipient, or 3) add a clause or condition to the subrecipient agreement to verify that an entity that may submit invoices for federal grant-funded activities has not been debarred or suspended prior entering into the agreement with the subrecipient. Name of Responsible Person: Patricia Kepner, Controller Projected Implementation Date: March 31, 2025

We will amend our existing procurement policy to address suspension and debarment for contractors when using federal grant funds to ensure compliance with federal regulations. We will implement a procurement checklist to document and verify contractor eligibility on SAM.gov prior to engaging in contracts utilizing federal funds.

Auditor Description of Condition and Effect. During our single audit testing, it was determined that there was no process in place to verify that vendors with transactions in excess of $25,000 were not 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 review its policies over suspension and debarment review to ensure that they are contracting with allowable vendors. Corrective Action. For Federal grants, management will implement a system for verifying that all vendors or subrecipients with transactions exceeding $25,000 are not suspended or debarred by the federal government, ensuring full compliance with federal regulations and minimizing the risk of using prohibited vendors. A mandatory check against the System for Award Management (SAM) database for suspension and debarment status will occur, with a printout or screenshot of the results maintained. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. January 31, 2025

Finding Number: 2024-001 Condition: The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Planned Corrective Action: Upon notification of the deficiency, a root cause investigation on the actions involved during the Grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the Finance Department, which includes Purchasing Division, Operating Departmental procurement requestors using federal grant awards and all Accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements. Contact person responsible for corrective action: Michael Kennedy, Finance Director Corey Jarocki, Deputy Finance Director Anticipated completion date: 11/19/2024

M anagements Response/Corrective Action Plan: The City of Sault Ste. Marie has instituted the following measures to remedy this deficiency to be implemented immediately. 1. Management learned of this deficiency in response to a request for documentation of a check for debarment in connection with the single audit field work in October 2024. Upon further i nquiry, City staff didn't have documentation of this kind. This task slipped through the cracks because a process was not in place to ensure it was completed. 2. In reference to the City's Uniform Guidance Policies, most recently approved by the City Commission on February 5, 2024, page 43, the City will include a suspension/debarment clause in all written contracts in which the vendor will certify that it is not suspended or debarred. Alternatively, the city may request vendor/contractor sign a certification regarding suspension or debarment. Executed certificates and procurement files will be retained by the City Clerk's office. This language was in the policy but was not implemented. 3. A sample certificate is provided on page 51 of the unform guidance policy. This sample certificate, if completed, would have provided evidence but was not implemented. For future contracts, this certificate will be completed prior to the bid award and documentation that it has been completed will be required for future City contracts that are part of a federal grant award. 4. If for any reason this signed certificate is not available prior to the award bid recommendation, City staff will check the vendor's status on Sam.gov and will document the results in the narrative of the memo. This will be required for all contracts related to federal grants. City staff will be provided instructions about how to check the status as by the State of Michigan in the following link... https://www.michigan.gov/msp/-/media/Proiect/Websites/msp/EM HSD/gra nts2/instructions for checking for excluded debarred contractors revised 72020.pdf?rev=0a928fb6b4b54253b2a627f1eb70dcd8&hash=31DC61AC1AB1E38D5A84952C43D27 F82 5. Going forward, City staff will add a note to the narrative of the agenda memo in BoardDocs to state whether the City has a certificate or found that the vendor was not suspended or debarred and provide documentation to be attached to the memo for all bid award recommendations. For example, we might indicate that the vendor/contractor was checked on Sam.gov and the contractor was not suspended or debarred and then follow up with a signed certificate when the contract is signed. Alternatively, a copy of the certificate, if separate from the contract, can be attached to the requisition in the P0 module. 6. This updated process will be shared with all project managers and grant administrators, along with staff in Finance and Clerks offices, so that we can ensure it is completed with each contract and project managers are supported during the busy construction season. 7. When bid award agenda memos route through Finance, they'll be reviewed to ensure this task has been completed and documentation is provided. This corrective action is being implemented as of this date and is expected to fully resolve the deficiency. Thank you for this opportunity for improvement. Sincerely, Kristin M. Collins Finance Director/Treasurer

Management at the Central Maine Growth Council is aware of its responsibility under 2 CFR 200.516(a) as it relates to the requirements to perform control activities related to suspension and debarment. • All recipients of expenditures under federal grants will be compared to the Office of Inspector General’s Exclusion Database to help ensure they are permitted to receive federal funding. This verification process will be documented and retained. • A written formal procurement policy and conflict of interest policy will be established. Responsible party: Garvan Donegan, Director of Economic Development and Strategic Projects (207) 680-7300 Anticipated completion date: December 31, 2024.

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Completion Date: September 30, 2024 Responsible Party: Michaela Arndt, County Clerk

Program: AL 21.027 - COVID-19- Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: 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 debarred and such procedure will be adequately documented. Anticipated Completion Date: August 16,2024 Responsible Party: Dixon County Board of Supervisors: Don Andersen, Deric Anderson, Roger Peterson, Neil Blolun, Lisa Lunz, Terry Nicholson, and Steve Hassler.

Management's Response: KC CARE Agrees Views of Responsible Officials and Corrective Action: This appears to be an isolated incident where the vendor was not entered at the correct time in our contract management database. But, in response to this incident, management created a clearer policy and outlined the timing of entering new vendors into the database and then making sure to do initial exclusion check during procurement process. Responsible Official: Dennis Dunmeyer, COO Anticipated Completion Date: Already implemented.

Conditions 1-2: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 3: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 4: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

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.

Response to finding 2023-002 – 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 2023-002. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, 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.

Thomas Swabb, Tribal Chairman Marjianne Yonge, Tribal Treasurer PO Box 747 Lone Pine, CA 93545 (760) 876-1034 Condition During testing we noted the following:For 1 of 1 vendors tested, the Tribe did not maintain documentation demonstrating that the vendor was verified as not federally suspended or debarred prior to entering into the contract. Corrective Action: Effective January 1, 2026, every proposal or contract that goes out will require all vendors to be active in SAMS.gov for all federal grants. This will be a requirement during the biddingprocess. Anticipated date of completion: January 30, 2026.

Finding 2023-001 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment (Material Weakness) Condition: An effective internal control system was not in place at the District in order to ensure compliance with requirements related to the grant agreement and the simplified acquisitions procurement method of the Procurement and Suspension and Debarment compliance requirement. Context: There were two contracts subject to procurement and suspension and debarment during the year. For both procurements, the District could only provide final signed contracts and did not have evidence of the full bid process. For the first selection, the District provided the request for proposal but did not provide all bids that were received or a scoring rubric to support why the District selected the vendor. For the second selection, the request for proposal, bids received, and scoring rubric were not provided. Additionally, evidence of a suspension and debarment check for both selections was not available. The District did not have a formal procurement policy documented. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that a procurement policy is adopted and followed and documents to support the process and vendor selections are maintained. Responsible Party and Timeline for Completion: The Treasurer is the responsible party. The completion will go into effect immediately.

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - 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

(2023-004) Documentation of Purchasing Compliance - Significant deficiency Criteria Per CFR §180.300 and 2 CFR §200.214, the District must verify vendors are not suspended or debarred or otherwise excluded from participating in a covered transaction. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA); collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity. Condition During our testing of suspension and debarment compliance, we noted that the District did not retain documentation demonstrating that vendors were verified as not suspended, debarred, or otherwise excluded from participation in federal programs prior to execution of two contracts, each with expenditures exceeding $25,000. Cause The District did not have formalized procedures to ensure suspension and debarment verifications were performed and documented prior to executing covered contracts. Effect Without adequate verification and documentation, there is a risk that the District could contract with vendors who are ineligible to receive federal funds, resulting in noncompliance with federal regulations. Questioned Costs No questioned costs were identified as a result of our procedures. Context/Sampling Two vendor contracts with expenditures greater than $25,000 were selected for testing. In both cases, the District did not provide documentation of suspension and debarment verification at the time of contract execution. Recommendation We recommend that the District implement procedures to verify vendor eligibility prior to entering into federally funded contracts. Acceptable methods include retaining a SAM.gov screenshot, obtaining vendor certification, or including a suspension and debarment clause in the contract. The District should also ensure documentation is retained in the procurement file and assign responsibility for this task to appropriate staff. Training and periodic reviews should be conducted to reinforce compliance and reduce the risk of using ineligible vendors. Management’s Corrective Action Planned Management concurs with the recommendation. IVGID will implement a procedure to document the procurement process and review of suspension and debarment for all vendors that undergo the bidding process.

Fiscal Year 2023 Single Audit Corrective Action Plan Finding Number: 2023-004 Procurement Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into contracts for services under the grant. Also, the CMHSP did not verify that the vendors were 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. Planned Corrective Action: The finance team will make sure proper bids and documentation are kept as proof of sole source provider and why certain vendors were chosen over others. The finance team will ensure that any procurement for vendors are shared with the contract management team to verify that the vendors were not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract. Contact Person: Kevin Hartley, CFO 231.633.2171 Kevin.hartley@nlcmh.org Anticipated Completion Date: 10-1-24

Views of Responsible Officials and Planned Corrective Actions: Agree with recommendation. Prior to executing a contract, employees with responsibility for engaging contractors and consultants funded by a Federal award will be required to check SAM.gov. This step will be included in the procurement policy.

FINDING 2023-003 Finding Subject: COVID-19 – State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Bob G. Courtney, Mayor Contact Phone Number and Email Address: 812-265-8300/mayor@madison-in.gov Views of Responsible Officials: We concur with the finding regarding the lack of policies or procedures in place related to the SLRF suspension and debarment requirements. Description of Corrective Action Plan: Historically, the city has not had a centralized position who would be responsible for grant and compliance management which created an inferior process of internal controls. A new Project & Grant Manager position was created in the Mayor’s office in April 2025. When contracts for goods or services equal or exceed the required amount, verification will be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the transaction with that person. Proper education on the process is already underway. Anticipated Completion Date: The new position referenced above has been filled and is in operation as of April 8th 2025.