Corrective Action Plans

Community Project Funding/ Congressionally Directed Spending - Construction Community Project Funding – Assistance Listing No. 93.493 Recommendation: We recommend that the Organization formally documents its existing procurement and suspension/debarment practices in written policies that comply with 2 CFR Part 200. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The instance identified by the auditors was related to the Organization not having a written policy that documents its existing procurement and suspension/debarment practices. The Organization has outlined its response in the bullet points below: • The Organization implemented a formal, written policy that details their procurement and suspension/debarment practices and will follow this policy moving forward. Name(s) of the contact person(s) responsible for corrective action: Brian Holcomb, Controller Planned completion date for corrective action plan: Has been implemented If there are questions regarding this plan, please call Brian Holcomb, Controller, at 612-638-4900.

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

Finding 2025-001 - Material Weakness Condition: Two (2) Next-Generation Facility Project (the Project) consulting contracts were procured in compliance with the Federal Transit Administration's (FTA's) procurement guidelines but did not conform with the Caltrans Local Assistance Procedures Manual (LAPM) Sections 10.01 and 10.1.9 of the LAPM, including not including a Public Interest Finding for the sole source procurement of the agreement, and the LeFlore group, LLC non-A&E consultant contract procurement did not comply with Section 10.3 of the LAPM. In addition, a Disadvantaged Business Enterprise goal was not requested nor completed as part of the advertisement for the project, which was required under Section 9.7.2 of the Caltrans LAPM. Recommendation: The Authority add additional language to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the Federal Highway Administration (FHWA). Management's Response: Management will ensure additional language is added to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the FHWA. The action will be completed with Board adoption of an updated Procurement Policies and Procedures Manual at or before its regular June 18, 2026, meeting. The contact person responsible for this action is Matthew Mauk, Executive Director, (530) 634-6880.

Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2025-2026

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.

Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a Suspension and Debarment certification from the contractor. Anticipated Completion Date: April 30, 2026

2025-002 US Department of Education Material Weakness in Internal Control over Compliance Material Noncompliance Procurement Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over procurement requirements. Corrective Action: One City adopted a new procurement policy and while it was implemented, documentation that the procedures were performed were lacking. In addition, One City has developed a training tool so that all staff who have purchasing authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

Management concurs. The City will strengthen its procurement policies for purchases with federal funding through regular training and clear communication to all relevant staff members. This will be implemented by September 2026.

Recommendation: The Department of Transportation should strengthen internal controls over consultant payments for extra work. Corrective Action Plan as Reported by the Department of Transportation: The CTDOT Transit Design Unit has immediately put in-place a corrective action plan, which will be completed by January 30, 2026. As part of this action plan, when signing off on invoices in the future, the Project Manager will ensure the date of the invoice refers to the correct payment mechanism or extra work letter in accordance with our established policies. This will strengthen internal controls and reviews over payments for all fee letters to ensure it follows established policies and only pay for properly authorized extra work. In addition to internal actions, the consultant project team will be counseled for submitting an invoice that does not follow CTDOT policies. Anticipated Completion Date: January 30, 2026 Department of Transportation Contact Person: Jonathan Kang, Transportation Supervising Engineer Jonathan.Kang@ct.gov, (860) 594-2754

Reference Number: 2025-014 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Department Name: Division of Libraries Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0144 (2/4/2022 – 12/31/2026) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Division should review and enhance controls and procedures to ensure that it follows the State’s procurement policies for all contracts charged to the program. Explanation of disagreement with audit finding: The Department of State, Division of Libraries disputes the audit finding of “significant deficiency in internal control over compliance, other matters” on the basis that Title 29, Chapter 69 of the Delaware Code is inapplicable and exempts the purchase of services by libraries from the State procurement process, including construction. Without admission to any deficiency in the Division’s “internal control over compliance, other matters,” the Division of Libraries will review all internal controls and procedures to ensure compliance with the State’s procurement process. Action taken in response to finding: Legal review of the Department of State, Division of Libraries internal controls and procedures to ensure compliance with State procurement process. Name(s) of the contact person(s) responsible for corrective action: Michelle Strauss, Chief of Staff, Department of State Planned completion date for corrective action plan: No later than six (6) months from the date of submission of this response, or September 16, 2026.

Department: Administrative and Financial Services Health and Human Services Title: Internal control over Medicaid procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over Foster Care procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over CCDF procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over TANF procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over PDG procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over Health Disparities program procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over Summer EBT procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will update related policies to balance agency authority/responsibility with procurement best practices, clearly communicating risks and responsibilities. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: May 31, 2026, June 30, 2026, and September 30, 2026, respectively DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Administrative and Financial Services Health and Human Services Title: Internal control over SNAP procurement needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Department of Administrative and Financial Services (DAFS): The Department will develop a specific policy document that balances agency authority/responsibility with procurement best practices regarding contract dates, clearly communicating risks and responsibilities. The Department will create a companion communication document to this policy document for distribution purposes. The Department will spotlight the policy and communication documents in the OSPS monthly electronic newsletter to all agencies. The Department will post the policy statement and communications documents on the OSPS intranet site. The Department will integrate the new content into the draft OSPS Policy Manual. The Department will release the related module in the new, updated, digital OSPS Policy Manual. Department of Health and Human Services (DHHS): The Department will collaborate with OSPS and program offices to implement procedures to ensure the timeliness of procurement documents. Completion Date: DAFS: April 30, 2026 (first item), May 15, 2026 (second item), May 31, 2026 (third and fourth items), June 30, 2026 (fifth item), and September 30, 2026 (sixth item) DHHS: May 31, 2026 Agency Contact: DAFS: David Morris, Acting Chief Procurement Officer, OSPS, 207-624-7335 DHHS: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Special Education Cluster – Assistance Listing No. 84.027 Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Action Plan: CCPS Purchasing Department will make the following changes to our current purchasing policy manual to comply with the Audit recommendation above: Noncompetitive bidding (written justification and purchase desc. Docs require) $ 0 - 5K threshold. Informal bidding (3) price quotes required for $5k - $25,000 purchase threshold with no exceptions for MOI. Formal Bidding required at 25K or greater (ITB, RFP, RFQ’s etc) Require purchase justification for all purchases regardless of dollar threshold Require authorized signature approval based on our current dollar threshold for all purchases Name(s) of the contact person(s) responsible for corrective action: Nelson E. Sample, CPPO, Procurement Manager Planned completion date for corrective action plan: No later than June 30,2026

City Clerk will be putting the Grant award Policies and Procedures in place

FINDING 2025-004 Finding Subject: Special Education Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district will implement procedures for Procurement, Suspension and Debarment by following the listed steps: 1. Three quotes will be obtained for procurements between $50,000 to $150,000 by the district and contract be awarded. 2. Verification of Suspension and Debarment will be performed by a member of the business office in System for Award Management (SAM) or the district will collect the certification from the entity prior to entering into transactions with the selected entity. Anticipated Completion Date: 3/31/2026