Corrective Action Plans

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

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2024 FINDING 2024-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: We implemented policies and procedures in accordance with Uniform Guidance 2 CFR 200.214. Statement of Concurrence and Responsible Persons: We concur with the auditors' finding. Aracelis Suárez Finance Director Implementation Date: Fiscal year 2024-2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION; GRANT No. AM-22-0072 Name of Contact Person: Stacey Amundson Corrective Action: When the Glasgow City Council adopts a revised purchasing policy, it will include the process to run a background check on the lowest responsible bidder of a project and check the SAM system for all required entities before awarding the contract. Proposed Completion Date: June 2025

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will ensure all new vendors will sign a suspension and debarment agreement prior to any payments being made. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: March 31, 2025 If the Cognizant or Oversight Agency has questions regarding this plan, please call Kelly Baldwin, Director of Finance at 410-239-3200.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ASSISTANCE LISTING No. 97.036 Name of Contact Person: Angela Newell, Administrative Officer Corrective Action: Carbon County is revising our procurement policy to include suspension and debarment requirements. This policy contemplates additional contract requirements to ensure both primary and subcontractors certify their eligibility for awards and/or subawards under Executive Orders 12549 and 12689, 2 CFR part 180, as well as, an internal check through the contract approval process via the Commissioners’ Office. Proposed Completion Date: July 2025

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to the SAM.gov website and CFR 200 guidelines. However, the department that applied for and accepted the grant failed to include CFR 200 Appendix II in the Professional Services Agreement and did not document the review of contractor status on SAM.gov. To address this, the City will provide targeted training for departments and staff involved in grants, focusing on compliance with grant policies, special provisions, and proper documentation of actions. Responsible Individual(s): Anna Guiles, Assistant Community Development Director Anticipated Completion Date: To be completed by 3/31/2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: City Manager Corrective Action: Employee training has been completed with all department heads to ensure future compliance with federal debarment requirements. We will do annual staff training on this and will work with our engineers to make sure they too are complying with the requirements. Proposed Completion Date: Ongoing

Corrective action plan: The Purchasing and Historically Underutilized Business Services (PHS) unit within PCS will provide additional mandatory training to staff responsible for vendor compliance checks. PHS will also revise the current Vendor Compliance Checks Procedure to include the evidence required to document compliance, including the run date. Furthermore, PHS management will establish a process for reviewing and approving the Form 1400 Procurement Checklist, regardless of the monetary value, to guarantee that vendor compliance checks are executed accurately and timely and in advance of covered transactions. Implementation dates: March 31, 2025 Responsible persons: Sonya Bebley, Director of Purchasing and Historically Underutilized Business Services, Procurement and Contract Services Department

Views of Responsible Officials and Planned Corrective Action: The Department will require all ARPA recipients provide a copy of their current/active registration with Sam.gov with each disbursement request. Moving forward, the Department will require any/all sub recipients with subrecipient monitoring under 2 CFR § 200.214 and subject to 2 CFR Part 180 to provide proof prior to execution of a grant agreement. Once implemented, we will provide staff training to understand what documentation is required prior to execution of an agreement and disbursement of funds. Independent testing of the established controls will be performed by Department Fiscal staff who have no role in the contracting process and this testing will be documented. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 Name of contact person: County Commissioners Corrective Action: The County Commissioners will work closely with the architects and engineers to ensure that this requirement is met for future projects. Proposed Completion Date: Immediately.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: Fallon County Commission/Clerk and Recorder Corrective Action: Procedures will be developed that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

The County will set up procedures to ensure reviews are performed that vendors are not excluded or disqualified.

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts for twelve contracts of a total of twenty-eight selections (43%) tested. Recommendation: We recommend that the Department enhance its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: Management disagrees with this finding. KDHE disagrees with this finding. KDHE has an established process in place which is documented in the Procurement Policies and Procedures manual that was provided as part of the audit request which shows that verification of suspension and debarment in the System for Award Management takes place prior to contractual agreements being fully executed as part of the agency’s established process. There is no requirement that KDHE is aware of that requires that the date of verification be documented. Action taken in response to finding: KDHE will make sure the date the verification was done is on the documentation. Name(s) of the contact person(s) responsible for corrective action: Kelly Chilson, Director of Procurement Planned completion date for corrective action plan: Immediately when new contracts are being created.

Management will review and clarify our procurement policies and procedures to ensure alignment with Uniform Guidance. We will clarify what documentation is sufficient to justify a lack of competition for purchases greater than the micro-purchase threshold. We will reinforce the need to document procurement decisions prior to entering into the procurement process and adequately retain the documentation by issuing targeted communication and presenting at various standing research administration staff meetings. Completion Date: December 31, 2025 University Contact and Responsible Party: Krystina J. Gross, Associate Vice Chancellor for Finance and Sponsored Projects, (314) 935-2073

Condition: There is no evidence the Road Commission performed a check to verify contractors were not suspended or debarred Planned Corrective Action: The Road Commission for Oakland County will establish formal policies around the internal review of contractors to ensure they are not suspended or debarred. In addition, the policy will ensure formal documentation of this review is maintained in the associated project. Contact person responsible for corrective action: Tim Becroft, Finance Director Anticipated Completion Date: 02/10/2025

The Town of Chelmsford, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY 2024-001 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The Town has implemented procedures to 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: Town Management and Finance. Planned completion date for corrective action plan: Completed.