Corrective Action Plans

Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency will revise its procurement policy to fully align with the requirements of 2 CFR Parts 200.317-200.327, including procedures for all required procurement methods. This revision is being coordinated with the broader update to the Fiscal Policy and Procedures Manual currently underway to ensure consistency across all organizational policies. The CFO and CAO will work jointly to implement and monitor corrective actions in cross-functional areas, including timekeeping, payroll documentation, record retention, lease tracking, IT access controls, vendor onboarding, procurement documentation, and personnel training. This shared structure is intended to ensure that policy revisions are supported by clear workflows, staff training, documentation standards, and periodic compliance review. We note that no purchases during the audit period met the threshold requiring formal competitive bidding, and no questioned costs were identified. By September 30, 2026, the Agency will complete updates to procurement procedures.

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

Using the DHS Contract Lifecycle Management (CLM) System, the Office of Procurement Services (OPS) reviews all contract requests (new, amendments, renewals, and extensions) for compliance with the State Purchasing Act. During the review, OPS will inform the program of any requests that do not comply with the Procurement Rules and Regulations before the contract is fully executed, providing a list of alternative exempt vendors. The contract will be halted until DHS is notified and approval is granted, or until a solicitation is posted and awarded. Senior-level staff in OPS will also review all requisitions for goods not processed through CLM to ensure that purchases comply with the State Purchasing Act. A spend analysis is conducted on purchases not exempt from the State Purchasing Act to determine whether the associated NIGP Code Category is above or below the bid threshold. If the NIGP Code is or may be above the bid threshold, precautionary steps are taken to ensure that the Department of Human Services remains in compliance with the State Purchasing Act (i.e., suggesting exempt vendors, halting the purchase until DHS is notified and approval is granted, or until a solicitation is posted and awarded).

The District is in the process of updating the Federal Procurement Procedures with the new thresholds that were issued in September. The District will get quotes for all items purchased with Federal funding in the future to avoid future findings. New Philadelphia City School District makes every effort to procure items based on the policies and procedures in place. We also follow the Uniform Guidance to the best of our ability.

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.

The Town will revise procurement procedures to ensure that written contracts are executed prior to the commencement of work for material projects. Procedures will include emergency procurement protocols consistent with 2 CFR §200.320(c), requiring written justification and documentation when public exigency is used. Staff will be trained on federal procurement requirements, including contract execution and documentation standards.

The Town of Spruce Pine will update its written procurement policies to fully incorporate current federal procurement standards under 2 CFR §§200.317–200.327 and applicable state procurement regulations. Management will provide training to staff involved in procurement and contract administration. The Town will also establish an annual policy review process to ensure procurement procedures remain current and compliant.

Corrective Action Plans Finding 2025-001 – Noncompliant procurement policy Corrective Action Plan: The Village will update its written procurement policy to comply with applicable State, local, and tribal laws and regulations and with Federal requirements under 2 CFR §200.317–200.326. In addition, the Village will train personnel on the updated policy. This policy will apply to all purchases of goods, services, and construction funded in whole or in part by Federal awards administered by Village of Hazel Crest, including subrecipients and contractors, unless superseded by more restrictive State, local, or tribal law. Person(s) Responsible: Amanda Page-Horvet, Accounting Supervisor Timing for Implementation: Fiscal Year 2027

Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, and compliance with applicable requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Policy was voted on by the board and put into place subsequent to year end.

2025-00I Condition: The center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Auditor's Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR §§ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Corrective Action Plan Finding 2025-001 Information on the federal program: Federal Program Name: Congressional Directives Federal Agency: U.S. Department of Health and Human Services Federal Assistant Listing and Title Number: 93.493 Award Year: September 1, 2024 to August 31, 2025 Criteria or Specific Requirement: Procurement, Suspension and Debarment Condition: The District is required to have procedures to ensure vendors are not suspended or debarred prior to charging services to the grant, as well as required to follow their own documented procurement procedures which should conform to the Uniform Guidance procurement standards. Correction Action Planned: The District has reviewed the applicable requirements of the Office of Management and Budget Uniform Guidance for procurement standards, specifically those related to the requirement for procedures to be documented regarding suspension and debarment and noncompetitive procurement. The District acknowledges that their procurement policy does not currently conform to the Uniform Guidance procurement standards, and formal procurement methods were not utilized for certain grant expenses. At the time of procurement, the District operated under the understanding that engagement of a vendor holding a General Services Administration (GSA) contract was consistent with and would satisfy applicable procurement requirements. Upon further review, the District recognizes that this assumption did not, in itself, meet all Uniform Guidance requirements, particularly with respect to documentation and justification of procurement methods. To ensure compliance with Uniform Guidance going forward, the District will implement corrective actions. The District will update the current procurement policy to ensure compliance Uniform Guidance. The District will provide formal training to existing grant Program Managers on Uniform Guidance procurement standards. Additionally, for any new grant opportunities, the grant committee will receive training on Uniform Guidance procurement standards prior to the completion of grant applications. For both existing and future grants, any proposed contracts or purchases exceeding $3,000 will be subject to review by the grant Program Manager (or the Grant Committee lead, if a Program Manager has not yet been assigned) to ensure that the appropriate procurement method is utilized, all required documentation is obtained and retained, and compliance with all applicable procurement standards is verified prior to purchase or execution of any contract. Contact Person (s) Responsible for Corrective Action: Ana Zavala, Chief Financial Officer Anticipated Completion Date: These corrective actions will be implemented immediately, with training completed by May 2026.

Single Audit Finding No. 2025-064 - Four of four judgmentally selected engineering and design-related professional service procurements were not publicly noticed on the Alaska Online Public Notice System. Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with this finding and recommendation. Corrective Action (corrective action planned): Department management and procurement officers will ensure that DOT&PF follows applicable statute and policy and will implement additional controls to ensure equitable and fair procurement public notice policies are followed. Completion Date (list anticipated completion date): June 30, 2026 Agency Contact (name of person responsible for corrective action): Michael White, Financial Services Manager

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