Corrective Action Plans

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. Kayla Quick, Accounts Payable Clerk. 6/30/2026

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook acknowledges the procurement deficiency identified in Finding 2024-001. The County previously developed and formally adopted a Federal Grant Procurement Policy on February 18, 2026, establishing procedures compliant with 2 CFR 200.317–327 and Appendix II, including required procurement methods, documentation standards, and inclusion of applicable federal contract provisions. The finding is reported as a repeat finding of prior years; however, the policy establishing these controls was adopted subsequent to the period in which the procurement activity under review occurred or during early implementation of the policy. As a result, the condition identified reflects a lapse in the consistent application of newly established procedures rather than a deficiency in policy design. To address this, the County has strengthened internal controls by requiring completion of standardized procurement checklists for all federally funded purchases and implementing enhanced supervisory review of procurement files to ensure that contracts and required federal provisions are included prior to execution and reimbursement. Additional guidance has been provided to staff to reinforce compliance expectations and ensure consistent application of procurement procedures. The County will continue to monitor procurement activities to ensure full implementation of established controls and anticipates that this finding will be resolved upon demonstration of consistent compliance in the subsequent audit period. Anticipated Completion Date: February 18, 2026 (Implemented)

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook acknowledges the procurement deficiency identified in Finding 2024-001. The County previously developed and formally adopted a Federal Grant Procurement Policy on February 18, 2026, establishing procedures compliant with 2 CFR 200.317–327 and Appendix II, including required procurement methods, documentation standards, and inclusion of applicable federal contract provisions. The finding is reported as a repeat finding of prior years; however, the policy establishing these controls was adopted subsequent to the period in which the procurement activity under review occurred or during early implementation of the policy. As a result, the condition identified reflects a lapse in the consistent application of newly established procedures rather than a deficiency in policy design. To address this, the County has strengthened internal controls by requiring completion of standardized procurement checklists for all federally funded purchases and implementing enhanced supervisory review of procurement files to ensure that contracts and required federal provisions are included prior to execution and reimbursement. Additional guidance has been provided to staff to reinforce compliance expectations and ensure consistent application of procurement procedures. The County will continue to monitor procurement activities to ensure full implementation of established controls and anticipates that this finding will be resolved upon demonstration of consistent compliance in the subsequent audit period. Anticipated Completion Date: February 18, 2026 (Implemented)

CORRECTIVE ACTION PLAN (Concerning Finding 2023-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook acknowledges the procurement deficiencies identified in Finding 2023-001. Subsequent to completion of audit fieldwork for fiscal years 2022 and 2023, the County developed and formally adopted a comprehensive Federal Grant Procurement Policy on February 18, 2026, to ensure compliance with procurement requirements under 2 CFR 200.317–327 and Appendix II. The policy establishes written procedures requiring documentation of procurement methods, inclusion of all applicable federal contract provisions, evaluation of responsible contractors, prohibition of geographical preferences, use of clear and accurate technical specifications, and implementation of affirmative steps to utilize small and minority businesses, women-owned businesses, and labor surplus area firms. Standardized procurement procedures and procurement checklists have been implemented to ensure required documentation and compliance reviews occur prior to contract award. The finding is reported as a repeat finding due to the timing of audit fieldwork, as the updated policies and procedures were adopted after the period tested. The County has implemented these corrective measures and will apply them to all federally funded procurements going forward to strengthen internal controls and ensure continued compliance with federal requirements. Anticipated Completion Date: February 18, 2026 (Implemented)

2023 – 007: Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Material Weakness Condition: During our review of the Organization’s internal controls over compliance related to the Title V major program, we noted that the Organization did not obtain prior written approval from the funding agency for the purchase of land and a building with Title V funds, with the purchase exceeding the $20,000 threshold included in the Title V contract. Additionally, the Organization did not have an approved budget that included these capital expenditures. The Organization also does not have an adequate system of controls established to identify, mark, record, or maintain equipment and real property purchased with federal funds, and no periodic physical inventory of such assets is being performed. Corrective Action Plan: Management will review internal control policies and procedures to ensure that prior written approval is obtained for all capital expenditures with federal funds. A procedure will be set up for maintaining property records, conducting periodic physical inventories, and ensuring all staff are trained on these requirements.

CORRECTIVE ACTION PLAN (Concerning Finding 2022-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook has initiated corrective action to address Finding 2022-001. Subsequent to the audit period and notice of the finding January 15, 2026, the County developed a comprehensive Federal Grant Procurement Policy that fully complies with the procurement standards of 2 CFR 200.317–327, including clearly defined micro-purchase and small-purchase thresholds and required procurement methods. The revised policy also establishes mandatory procedures for verifying and documenting contractor eligibility through Debarment and Suspension reviews using SAM.gov prior to contract award and requires inclusion of applicable federal contract provisions. The policy will be presented for formal adoption at the next available County Commissioner meeting scheduled for February 18, 2026. Upon adoption, these measures will strengthen internal controls over procurement compliance and reduce the risk of future noncompliance with federal procurement requirements. Anticipated Completion Date: February 18, 2026