Corrective Action Plans

YWCA will develop a written procurement policy that conforms with the Uniform Guidance. In addition, we will implement procedures and control processes to retain documentation supporting compliance with major federal compliance requirements regarding suspension and debarment.

2026-004 Procurement Corrective action planned: OMC will follow its current procurement policy and will seek bids for contracts with autorenewals, utilities, and professional services. However, OMC will also review its current procurement policy to see if changes are necessary to reflect the current environment to exclude items such as certain utilities and services from the bid process if such utilities and services are unique and limited to the service area of the health center and if only one option exists or the current vendor is performing sufficiently so that undue burden would be placed on the Organization to switch vendors, then a sole source justification will be documented, in both paper format and electronically so that records are readily available for review. Anticipated completion date: 08/31/2026 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

2026-001 Public Housing Capital Fund Recommendation: The Commission should implement policies and procedures to ensure all federal compliances are followed pertaining to Procurement, Suspension and Debarment. Action Taken: Management will implement policies and procedures to ensure the Commission is in compliance with all grant requirements pertaining to the Public Housing Capital Grant. Anticipated Completion Date of Action: October 31, 2026

Corrective Action Plan Finding 2025-002 Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Tim Stay, CEO Timeline: All future contract solicitations will follow the required procurement standards.

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Housing Hope adopted a Procurement Policy that aligns with the Uniform Guidance following year end. The policy was communicated to all staff with purchasing and procurement responsibilities. The policy will be reviewed at least annually to ensure continued compliance with the Uniform Guidance. In addition, management conducts periodic reviews of procurement practices to verify compliance with the Policy. Anticipated completion date: The Procurement Policy was adopted November 2025 by the Board.

Finding No.: 2025-013 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002, S403A240002 Area: Procurement and Suspension and Debarment Questioned Costs: $2,284,786 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding cost or price analysis and suspension and debarment requirements. GDOE recognizes that its procurement policies should clearly address the requirement to perform and document cost or price analyses for applicable procurements and contract modifications exceeding the simplified acquisition threshold. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement procedures should be reviewed periodically to ensure that applicable federal requirements are incorporated and that adequate controls are in place to demonstrate compliance. GDOE Supply Management Office will: 1. Review and update procurement policies to address the requirements of 2 CFR 200.324 for cost or price analysis. 2. Establish procedures and standardized documentation for cost or price analyses, including applicable contract modifications. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method, and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to ensure compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will be performed to verify that required cost or price analyses and suspension and debarment verifications are completed and documented.

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services in excess of $15,000, in which Auditor participated and was subsequently provided with the procurement operations and results, complete with Auditor’s own competitors. Vendor/Partner Contracts: The specific vendors and subcontractors were evaluated, vetted, and formally approved by the U.S. Department of Transportation (USDOT) during the competitive application and award phase of the Thriving Communities program. The Regulation: Under 2 CFR 200 (specifically regarding procurement by non-federal entities), if a federal awarding agency explicitly approves specific subrecipients or contractors as part of the federal award, it generally waives the requirement for subsequent competitive procurement for those designated roles. See USDOT-approved budget line items showing the named vendors (see USDOT Approved Budget” attached). All records are on file with the USDOT. Subrecipient/Contractor Monitoring: COMTO provided clear, signed agreements with these preapproved vendors that pass down all federal compliance requirements (e.g., Title VI, civil rights compliance, reporting metrics) required by the Thriving Communities program. Auditor has not clarified exactly which federal or local regulation they believe requires a rebid of USDOT-approved project partners (see executed contracts attached). COMTO does not run a competitive bidding or procurement process to select a subrecipient. They were selected as collaborative partners/sub-awardees and their status as subrecipients was explicitly authorized by the USDOT when they approved our grant award. All records are on file with the USDOT.

Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: Testing of the federal program identified the following: a. The Organization’s formally documented procurement policy is missing one required element as it relates to domestic preferences (2 CFR 200.322). b. Two lease agreements were entered into where the Organization did not follow the procurement process as detailed in the procurement policy. The lease agreements with the vendors were also missing a required contract provision in accordance with Uniform Guidance and there was no review performed by the Organization to ensure the vendors were not suspended or debarred as the lease agreements with the vendors were over $25,000. Corrective Action Plan: Management will implement a checklist to ensure the Procurement Policy is being followed. In addition, management will review the procurement policy elements and update our procurement policy to ensure it incorporates all required elements. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director and Christina Thoelke, Business Manager Anticipated Completion Date: September 2026

Finding Number 2025-228: The Division is not following Idaho Administrative Rules for Purchasing as required. Federal Program: 84.126 - Rehabilitation Services - Vocational Rehabilitation Grants to States Related to Prior Finding: N/A Agency’s view: The agency agrees with this finding. IDVR acknowledges that procurement practices during the audit period did not fully align with state procurement requirements. Corrective Action: IDVR has worked directly with the Division of Purchasing to revise IDVR procurement-related Policy Directive and is currently finalizing updates to align Agency procedures with state procurement requirements. Additionally, IDVR has developed draft procurement policies, procedures, and internal controls designed to strengthen compliance with both state and federal requirements. These materials have been reviewed with the Vocational Rehabilitation Technical Assistance Center and are currently undergoing RSA review. While awaiting final approval, IDVR has already begun strengthening procurement oversight and monitoring practices. Upon completion of the review process, IDVR will conduct agency-wide training and formally implement the updated policies and procedures. Additionally, IDVR will be developing monitoring dashboards that will provide leadership with enhanced visibility into purchasing activity and spending thresholds to support ongoing compliance with procurement requirements. These efforts reflect IDVR's commitment to establishing sustainable procurement controls that not only address the finding but also enhance transparency and accountability in purchasing activities. IDVR has also developed contracts for CRP services for both the General and Pre-ETS programs that have been approved by RSA for implementation. The Division is currently working on rolling out new CRP contracts with anticipated start date of 02/01/2027 to assure compliance with contracts for procurements for these services that are anticipated to exceed the $150,000 each state fiscal year and would not be covered under the updated policy directive due to this anticipated annual spend based on historical spending analysis for these services. Anticipated Corrective Action Date: February 1, 2027 Responsible for Corrective Action: Heidi Smith, Financial Officer Heidi.Smith@vr.idaho.gov (208) 287-6457

Finding Number 2025-206: The Commission is not following Idaho Administrative Rules for Purchasing as required for compliance with the requirements applicable to the Rehabilitation Services-Vocational Rehabilitation Grants to States program. Federal Program: 84.126 - Rehabilitation Services - Vocational Rehabilitation Grants to States Related to Prior Finding: N/A Agency’s view: The agency agrees with the finding. However, we have since corrected this finding, as it was found on the previous year’s audit. Corrective Action: In December of 2025, we received training from the Department of Purchasing. Based on that training ICBVI’s management team worked with DOP to create contracts for current and future purchases. ICBVI asked Laura Cortazar to take the lead on the development of contracts for the agency. ICBVI created a procurement checklist and documentation template, which was added to internal controls to support purchases subject to state policy. In August of 2026, all staff who make any purchases were trained using the new guidelines, which ensure compliance with state procurement requirements. In addition, ICBVI worked with DOP’s process to request purchasing exemptions for working with community rehabilitation programs, universities and with a temporary staffing agency. ICBVI understands the state thresholds and has processes in place for creating contracts when needed. ICBVI believes this finding is ready to be closed. Anticipated Corrective Action Date: August 2026 Responsible for Corrective Action: Laura Cortazar, Financial Technician lcortazar@icbvi.idaho.gov (208) 334-3220

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Stan Heil Contact Phone Number and Email Address: 812-542-0506-sheil@floydcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Floyd County has concurred with the material weakness finding and has accepted the recommendation provided of “we recommend that management of the County establish a proper system of internal controls and develop procedures to ensure that property and services are properly procured and that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards.” Floyd County will present all appropriate Requests for Proposal to the Commissioners for approval, publish in local arenas as required by statute, receive bids by defined deadlines, present to Commissioners for opening in a public setting, take under review with the County Attorney, and award according to statute timely. Dept of Treasury-Covid 19 funds, were paper files out for scanning and the County was unable to retrieve the specifics to support all needed functions requested during the Audit period. Documentation of past and future actions will be maintained in electronic retrievable format. All actions recommended and produced in this Corrective Action Plan have been, and will be adhered to for transparency, efficiency, and ethically. Anticipated Completion Date: The anticipated completion date of the Corrective Action Plan identified above will occur September 30, 2026 reporting as the exposure of this finding-weakness, is being addressed.

Management will develop, formally approve, and implement written procurement procedures that comply with the Uniform Guidance procurement standards in 2 CFR §§ 200.317 through 200.327 and will be approved by the Board of Directors.

Regarding Finding 2025-001, pertaining to procurement, the Pennsylvania Broadband Development Authority has determined that the vendor in question was a project manager and did not provide general contracting services. As such, the rules regarding procurement were inapplicable. Please see the attached email from the Pennsylvania Broadband Development Authority. Related to any corrective action regarding this finding, pertaining to any future federal monies, Church of the New Covenant commits to using documented procurement policies which conform to the procurement standards in 2 CFR 200.317 through 200.327. Church of the New Covenant will in the future maintain records which sufficiently detail the history of procurement, including the rationale for procurement method, selection of contract type, contractor selection or rejection, and the basis for contract price. In the future, a staff person will be assigned the responsibility for the implementation of supervisory review procedures, for the review and updating of the procurement policy and procedures, and for the development of a standardized procurement file checklist.

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. One contract tested did not contain all applicable Uniform Guidance contract provisions. In one instance involving contracts exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Corrective Action Plan: KCEC will update its procurement procedures to incorporate applicable Uniform Guidance requirements. Debarment checks will be completed and documented for all vendors prior to contract execution while also ensuring that contracts contain attestation that the vendor affirms they are not disbarred. Contracts will be reviewed to ensure all required federal provisions are included. KCEC's Grant and Compliance accountant will strengthen its contract review process to ensure federal guidelines and language is present and included in contract verbiage by actively participating in contract negotiations between the vendor and KCEC. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

FINDING 2025-018 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Vendor Setup & Conflict Verification: Standardized new vendor onboarding under the Purchasing Director. Requires W-9s, registration forms, annual SAM.gov suspension/debarment checks, state business registration checks, and local property tax searches to rule out employee/board conflicts of interest. Multi-Phase Procurement Overhaul: • Phase 1 (2025–2026): Established board-approval workflows for all contracts, quotes, and invoices. • Phase 2 (2025–2027): Enforced proper quote, bid, and special purchasing compliance. • Phase 3 (2026–2027): Updating board policies and internal controls to enforce federal uniform purchasing guidelines. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

FINDING 2025-013 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Enforced updated Internal Controls Manual purchasing thresholds and pre-approval workflows. Executing a multi-step resolution: board approval workflows established in 2025–2026, proper procurement/bidding compliance expanded through 2026–2027, and updating board policy to enforce uniform federal guidelines in 2026–2027. Anticipated Completion Date: June 30, 2027

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

The National Preservation Institute acknowledges the finding related to procurement documentation. While the National Preservation Institute believes its procurement activities were conducted in a manner consistent with Federal requirements, certain documentation necessary to demonstrate compliance was not retained in a manner that readily supported the procurement decisions. Management has reviewed the circumstances surrounding the finding and has reinforced expectations regarding procurement documentation, record retention, and compliance with Federal procurement requirements. Going forward, procurement files associated with federally funded activities will be reviewed to ensure that all required supporting documentation is generated and retained, including documentation supporting the basis for contractor selection, cost or price analyses, procurement method, and any other records required by Uniform Guidance. In addition, the National Preservation Institute will formally adopt a procurement policy designed to align with the procurement standards contained in Uniform Guidance, including requirements related to competition, conflict of interest, documentation, contractor selection, and procurement record retention. Management believes that the combination of a formal procurement policy and enhanced review procedures will strengthen compliance with Federal procurement requirements and ensure that procurement files contain sufficient documentation to support future monitoring, audit, and reporting requests.

Conditions – The Authority has a formalized procurement policy (the policy). However, the policy does not conform to applicable standards under Uniform Guidance because it does not include procedures to ensure the Authority does not enter into covered transactions with entities that are debarred, suspended, or otherwise excluded. We noted during our testing that there was limited documentation of the Authority's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Recommendation – We recommend that management strengthen their formal procurement policy using the guidance of 2 CFR 200.317 – 200.327. Additionally, management should follow this policy when procuring services or property and maintain the related documentation. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. Management is in the process of reviewing and revising its policies. Anticipated Date of Completion – Completed. Action Taken – In regard to the 2025 audit finding Procurement Procedure, the Loop Water Authority recognizes the shortcoming and has implemented the following action to remedy the finding: The sampled contract existed prior to the ARPA procurement requirements. The aforementioned contract was provided to legal representation for confirmation of compliance with all requirements and was stated to be, in compliance. The failure existed at the management level as not confirming SAM.gov or contractual verbiage. The Loop Water Authority corrective action was to hire a full-time Executive Director to provide oversight and operational compliance for all contracts. The Executive Director has implemented a checklist to review all new procurement contracts for compliance using standards from 2 CFR 200.317 – 200.327. Person Responsible for Corrective Action Plan – Jason Hann, Executive Director.

Management agrees with the finding. Management will spend additional time reviewing CFR Part 200 for familiarization. Policy templates will also be reviewed, and assistance will again be requested to develop/finalize the necessary policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

FINDING 2025-003 Finding Subject: Drinking Water State Revolving Fund – Procurement Contact Person Responsible for Corrective Action: Beth Stocking, Clerk-Treasurer Contact Phone Number and Email Address: 574-223-2510 clerk@rochester.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City concurs with the finding. The City will adopt and use written procurement procedures for purchases made with federal award funds that incorporate applicable 2 CFR Part 200 requirements and the terms of each federal award. Before a purchase or contract is initiated, the City will identify whether federal funds are involved and determine the required procurement method based on the applicable threshold and type of procurement. The City will use required competitive procedures, public advertising, and formal procurement methods when applicable. Architectural and engineering professional services will follow applicable qualifications-based competitive proposal requirements. Any permitted noncompetitive procurement will include documented justification. Procurement files will retain solicitations, quotations or proposals, evaluations, approvals, contracts, and documentation supporting the method and selection. The Clerk-Treasurer will coordinate review of federal procurement requirements with the responsible department and professional advisors before federally funded contracts are executed, and personnel involved in federal awards will be instructed on the procedures. Anticipated Completion Date: December 31, 2026, with the procedures to be applied immediately to new procurements involving federal award funds.

Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: • The District has not formalized and adopted a written procurement policy. • In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. • In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for the vendor selection. Corrective Action Plan: The District will develop and formally adopt a written procurement policy addressing procurement activities involving federal awards and the applicable requirements of the Uniform Guidance. The District will establish procedures to document the procurement method utilized and the basis for vendor selection, verify and retain documentation that vendors subject to federal suspension and debarment requirements are not suspended or debarred from participation in federal programs, and ensure that federally funded contracts include applicable federal contract provisions required by 2 CFR Part 200. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: March 2027

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that procurement procedures and related documentation requirements were not consistently followed and that adequate controls were not in place to ensure compliance with federal procurement standards. Management will conduct a comprehensive review of procurement policies and procedures and will implement formal review requirements for procurement method determinations. To support these efforts, management is hiring a Purchasing Coordinator who will be responsible for all aspects of the Organization’s procurement function and for ensuring that all purchases are conducted in accordance with the Organization’s written procurement policies and the procurement standards of the Office of Management and Budget (OMB) Uniform Guidance (2 CFR 200.317 through 200.327). Additional procedures will require documentation of price reasonableness, competitive quotations, sole-source justifications, and aggregate vendor purchase evaluations, as applicable. The Purchasing Coordinator will determine and document the appropriate procurement method for each purchase, obtain and retain required quotations, and maintain complete procurement files for all purchases charged to federal awards. Personnel involved in purchasing activities will receive additional training on Uniform Guidance procurement requirements, and management will implement monitoring procedures to verify compliance on an ongoing basis. To maintain appropriate segregation of duties, the Accounting Department will independently review procurement files before payment to verify that documentation is complete and that the selected procurement method is appropriate and compliant with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

In 2026, written procedures governing the allowability of costs charged to Federal awards and procurement activities involving Federal funds were developed, documented, and implemented. Responsibility for implementing and maintaining these procedures has been assigned to the Finance Department. The procedures address applicable Federal requirements for determining allowable costs and procurement activities and will be reviewed periodically and updated as necessary to maintain compliance with applicable Federal requirements.

Description of Corrective Action Plan: For any future projects funded with federal money, the City will ensure the federal procurement standards are followed. Anticipated Completion Date: Immediately, will be considered for any future procurements done with federal funds.