Corrective Action Plans

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

Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.

CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact Person Responsible for Corrective Action: Bruce Haggerty, Finance Director Corrective Action: The Houlton Band of Maliseet Indians will take the following actions to address finding 2025- 001: I attended Procurement Training (through Housing and Urban Development) on September 2-3, 2026. HBMI is in the process of updating our Procurement Policy to meet current federal standards. HBMI is also in the process of creating a checklist based on our Procurement Policy to help with assessing the applicable rules during each procurement. Staff will be educated on the new Procurement Policy and Procurement Checklist. Anticipated Completion Date: 9/30/2026

Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.

Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 audit occurred before the corrective measures became effective. Corrective measures implemented include policies and procedures designed to strengthen its procurement and contracting processes. These include: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work Management believes these corrective actions address the deficiencies identified and expects them to be fully effective for construction activities occurring after implementation.

Prior to awarding contracts over $25,000, we will conduct a review of the government website (SAM) to confirm contractors have not been suspended or debarred. Documentation will be retained to provide evidence of verification. While we do have a process to select vendors who provide us with the lowest costs, we will update our process to document the rationale on vendor selection on purchases over $2,500. We will update our procurement policy to reflect this process enhancement.

The EPI Center conducted a comprehensive review of all contractors subject to testing and verified, through alternative procedures, that none were suspended or debarred (e.g., verification through SAM.gov and documented vendor validation processes). As a result, all costs associated with these contracts were determined to be allowable, reasonable, and allocable to the federal award. Accordingly, management concluded that the finding relates to procurement policy implementation, documentation, and compliance processes rather than the allowability, allocability, or eligibility of the expenditures tested.

Management agrees with the finding and will develop and implement written procurement procedures consistent with Uniform Guidance requirements.

Finding 2025-002 – Policies and Procedures Require Review and Update – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Significant Deficiency Corrective Action Plan: Strengthening Board governance, ethical expectations, policy ownership, accountability, and delegated authority. Initial Deliverables • Code of Ethics; • Conflict-of-Interest Policy; • Whistleblower and Reporting Policy; • Delegation of Authority Matrix; • Spending and Approval Authority Matrix; • Signature Authority Matrix; • Policy Development and Review Policy; • Board Governance Framework; • Annual policy acknowledgment process; and • Governance training plan. Standardize the Housing Authority’s major operating processes and reduce reliance on undocumented institutional knowledge. Initial Deliverables • Standard Operating Procedure framework; • Priority SOP inventory; • Housing Choice Voucher processing SOPs; • Public housing occupancy and recertification SOPs; • Waiting-list administration SOPs; • Inspection scheduling and tracking procedures; • Intake and communication procedures; • Position-responsibility matrix; • Updated job descriptions; • Workload assessment; • Staff onboarding procedures; and • Cross-training plan. Improve financial accuracy, safeguarding of assets, segregation of duties, reconciliations, reporting, and management review. Initial Deliverables • Financial Policies and Procedures Manual; • Accounts-payable controls; • Check-run and payment-review procedures; • Payroll approval procedures; • Cash-handling procedures; • Laundry-revenue procedures; • Bank and general-ledger reconciliation procedures; • Monthly and annual financial-review checklist; • Audit-adjustment reconciliation procedures; • Fixed-asset and nonexpendable-equipment inventory procedures; • Capitalization policy update; • Investment policy update; • Creative Housing financial-accounting review; • Inter-entity transaction policy; • Corrective-action plan for questioned costs; • Financial close calendar; • CFO and Executive Director review responsibilities; and • Board financial dashboard. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: • Phase 1: Target Date of completion: November 30, 2026 o Implementation and Communication about the Red Flags Ethics Hotline o Identification and creation of needed policies and structural tools o Updating of current policies as needed • Phase 2: Target Date of Completion: April 30, 2027 o Training on new policies/expectations and accountability standards.

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.

Response and Views of Responsible Officials Management concurs with this finding. Management acknowledges that, during the audit period, the Organization did not maintain federally compliant written procurement procedures that addressed the requirements of Uniform Guidance for procurement transactions charged to federal awards. While the Organization generally followed purchasing and approval practices, those procedures were not formally documented and did not specifically address federal procurement standards, suspension and debarment verification, or procurement documentation requirements. Since the audit period, the Organization has substantially strengthened its procurement policies and internal controls. The Financial Policies Manual has been revised to include formal procurement procedures, purchasing approval requirements, competitive purchasing expectations, documentation standards, and financial oversight responsibilities. In addition, purchasing responsibilities have been incorporated into the Organization's strengthened internal control structure, including review by the internal bookkeeper, Executive Director, Executive Committee, and Board of Directors, as appropriate. Management also notes that strengthening procurement procedures was identified through the MIECHV monitoring process and was incorporated into the Organization's broader financial management improvements. Management believes these actions substantially improve compliance with federal procurement requirements and reduce the risks identified during the audit. Management has completed the following corrective actions: • Revised and expanded the Financial Policies Manual to include federally compliant procurement procedures and purchasing controls. • Established documented approval thresholds and purchasing authority for procurement transactions. • Implemented procurement documentation requirements, including supporting invoices, approval documentation, and retention of procurement records. • Strengthened internal review of procurement transactions through involvement of the internal bookkeeper, Executive Director, Executive Committee, and Board of Directors, as appropriate. • Incorporated procurement procedures into the Organization's broader system of internal financial controls and oversight. Management will complete the following additional actions: • Develop and implement written procedures for suspension and debarment verification for applicable federally funded purchases, including documentation of SAM.gov verification. • Develop a standardized Federal Procurement Checklist to document procurement method, approvals, required competition, suspension and debarment verification, and supporting documentation for federally funded purchases. • Establish standardized procurement files to ensure all required procurement documentation is maintained in accordance with the Organization's record retention policy. • Provide training to employees responsible for initiating, approving, or documenting procurement transactions charged to federal awards. • Conduct an annual review of procurement policies and procedures to ensure continued compliance with Uniform Guidance and federal grant requirements. Responsible Official: Josie Brittain Anticipated Completion Date: September 30, 2026

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following: --One instance where the Cooperative did complete price comparisons; however, the memo documenting the procurement did not reference the price comparison. The procurement file did not obtain all required components of the procurement process including rationale for selecting the vendor or the procurement method used. --One instance where the Cooperative did not follow the procurement process as detailed in the procurement policy and no documentation was retained to support the rationale for selection of vendor. Corrective Action Plan: The Cooperative has taken steps to remedy the findings of the 2025 single audit: --Management reviewed procurement policies with department heads that are responsible for contractor and material procurement for grants. --Accounting staff will now review all grant expenditures at least monthly to catch new vendors in a more timely manner and assure that appropriate procurement policy has been adhered to prior to contractor starts work or material is used on projects. Responsible Individuals: Jeremy Richert, Chief Executive Officer and Kelly Gibbs, Chief Financial Officer Anticipated Completion Date: July 2026

Finding 2025-003 Federal Agency Name: United States Department of Health and Human Services Program Name: Congressional Directives FFAL #93.493 Finding Summary: Testing of the federal program identified the following: 􀁸 The Hospital’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. 􀁸 Instances where the Hospital did not follow the procurement process, and/or retain documentation for reasoning of selection of vendor. Corrective Action Plan: For Finding 2025-003, the Hospital has updated and approved its Federal Procurement Policy and Procedure to incorporate all required elements of Uniform Guidance and strengthen compliance with federal grant requirements. In addition, the Hospital revised its Capital Request process to include formal procurement requirements, vendor selection documentation, and approval workflows. Effective immediately, no federal funds will be expended until the procurement process has been fully completed and documented in accordance with the revised policy. Management has implemented controls to ensure procurement records are maintained, including documentation supporting vendor selection and purchasing decisions. To support compliance and consistent application of the new requirements, education and training on the revised procurement and capital request processes will be provided to all managers on August 5, 2026. Hospital leadership will monitor adherence to these procedures through ongoing review and oversight to ensure compliance with federal regulations and prevent future occurrences of this finding. Responsible Individuals: Wesley Babers, Chief Executive Officer and Ashley Jaramillo, Chief Financial Officer Anticipated Completion Date: August 2026

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE

FINDING 2025-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas Dippel, CPA Contact Phone Number and Email Address: (812) 683-2211 / ct@huntingburg-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with the City’s attorney to revise its current policy to include federal regulations and procedures related to Procurement and Suspension and Debarment. Once revised, the City will follow its policy to ensure compliance with the compliance requirement. Anticipated Completion Date: September 30, 2026

FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that price reasonableness analyses are performed and documented prior to entering into agreements with vendors in accordance with Uniform Guidance procurement requirements. The University will implement the following corrective actions: • Continue to monitor and review procurement policies and procedures for changes in applicable federal requirements and institutional practices. Procurement policies, procedures, and related documentation tools will be updated as necessary, and the standardized procurement checklist will be periodically reviewed and revised to ensure alignment with current procurement policies and Uniform Guidance standards. • Require supervisory review of procurement transactions to ensure all required procurement documentation, including price reasonableness determinations, is completed and retained prior to final approval of vendor agreements. • Provide training to procurement and departmental personnel involved in federally funded procurements regarding Uniform Guidance requirements and documentation standards. • Conduct periodic monitoring of procurement files to verify ongoing compliance with procurement policies, procedures, checklist requirements, and applicable federal regulations. These corrective actions will strengthen the University's internal controls over procurement activities and help ensure compliance with Uniform Guidance requirements related to procurement documentation and vendor selection. Individual(s) Responsible for Corrective Action Plan: Randi Vandegrift, Strategic Sourcing Manager John Skjeveland, Controller Estimated Completion Date: September 30, 2026

Planned Corrective Action: Management plans to develop and formally adopt a comprehensive written procurement policy that aligns with the procurement requirements in 2 CFR 200.317–.326, including provisions addressing methods of procurement, competition, conflicts of interest, required contract clauses, and documentation standards for federally funded purchases. The policy will distinguish between micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurements, and will specify the documentation required for each method. In addition, the District will establish and implement procedures to verify, prior to award, that all contractors and vendors for covered transactions are not suspended or debarred, typically by performing searches in SAM.gov or obtaining appropriate certifications, and will maintain printed or electronic evidence of those checks in the procurement file. The District will incorporate a procurement checklist or approval form that must be completed and signed by the procurement o􀀁icer and reviewer, a􀀁irming that required suspension and debarment verifications and other Uniform Guidance requirements were performed for each covered procurement. Management will also provide periodic training, at least annually, to sta􀀁 involved in procurement and grant administration on the Uniform Guidance procurement standards and suspension and debarment requirements, and will perform periodic internal reviews of a sample of federally funded procurements to confirm that the written policy and documentation requirements are consistently followed. Results of such reviews will be reported to management and the governing board to reinforce accountability and drive continuous improvement in the District’s internal control over federal awards.

The Shaquille O'Neal Foundation acknowledges the observation regarding the documentation requirements under 2 CFR §200.318(a). While the Foundation did not have a formal written procurement policy in place during the audit period, it did implement procurement practices designed to comply with the Uniform Guidance requirements. Specifically, the Foundation maintained oversight of contractor performance in accordance with 2 CFR §200.318(b) by ensuring that all contractor agreements and applicable purchase orders incorporated the required federal contract provisions and procurement language. The Foundation monitored contractor performance to verify that work was completed in accordance with the terms, conditions, and specifications of each agreement. The Foundation recognizes that documenting these procurement procedures in a formal written policy is a separate requirement under 2 CFR §200.318(a). To address this deficiency, management has developed and adopted a written Procurement Policy that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). The policy formalizes the Foundation's procurement procedures, internal controls, competition requirements, contract oversight responsibilities, and documentation standards to ensure ongoing compliance with federal regulations. Management believes this corrective action fully addresses the audit finding and strengthens the Foundation's procurement governance for future federal awards.

2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Responsible Party: Emma McQuillan, Chief Financial Officer Completion Date: 12/5/2024

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

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

Procurement – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Review Contract and procurement policies and procedures. • Compare current procurement process and training to the policies and identify areas for correction and improvement. • Update Policies and procedures as needed. • Implement procedures to review vendors on a periodic basis. • Implement procedures and assign responsibility for checking off that procurement documentation exists and is in the vendor folder or designated area. • Retrain staff involved in procurement on updated procedures. • Monitor process and adjust as needed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: January 2027

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the procurement and suspension and debarment compliance requirements under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE respectfully clarifies that the Department does have established processes and internal controls related to procurement activities, including those applicable to federally funded programs such as IDEA. The procurement procedures in place are consistent with applicable federal regulations, including 2 CFR §200.317 and 2 CFR §200.318(a)(i), as well as applicable Commonwealth of Puerto Rico laws and regulations. However, the PRDE acknowledges that the timely delivery of procurement documentation and the organization of contract records for IDEA-funded programs require improvement. The deficiencies noted are attributable primarily to delays in making documentation available to the auditors within the requested timeframes, and to the need for improved coordination between the IDEA program office and the Purchase Department of PRDE, which handles certain quotation processes IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Administration and Transportation Unit Alayra Figueroa Gonzalez Associate Secretary for Special Education

Management has since adopted a formal policy stipulating compliance with State of Mississippi procurement and Federal procurement requirements. A written standard of conduct for employees engaged in contract selection, award, and administration is in process and expected to be formally adopted in the near future. Completion Date: Pending Name of Contact Person Responsible for Corrective Action Plan: Rachel Quave

Condition: The Corporation’s procurement and suspension/debarment policies and procedures were not in conformance with Uniform Guidance requirements. In addition, procurement records for the items tested did not contain sufficient documentation to support the procurement method used, the basis for contract selection, or compliance with suspension and debarment requirements. Planned Corrective Action: The Corporation will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and should implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Contact person responsible for corrective action: Michelle Toups and Brian Balutanski Anticipated Completion Date: 1/1/2027