Corrective Action Plans

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

Corrective Action Plan Year Ended December 31, 2025 Finding 2025-001 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Corrective Action Plan: To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed introduced a Purchasing Compliance Program in November 2025. This program included training and oversight procedures for procurement. The training included ongoing quarterly purchasing training for end users and purchasing staff and new hire training. The purchasing team maintains training documents and ensures new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures are performed by the Assistant Director of Supply Chain Management and include auditing of purchase orders over the micro-purchase threshold to ensure proper documentation is present. We believe these steps address the procurement findings that have been identified; however, additional controls have been implemented to further ensure compliance. In January 2026, an additional approval step was added to the purchase requisition approval workflow in the procurement system for all federal procurements above the micro-purchase threshold. This step documents review and approval by the Assistant Director of Supply Chain Management or the Director of Finance after reviewing the procurement to ensure compliance with procurement requirements and policies. In addition, Texas Biomed is developing a new sole source justification form for the end users to use. This will include more detail to better document sole source justification, and the end-users will be advised of the new format and how to use it. The Assistant Director of Supply Chain Management also leads efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training November 2025 • Oversight procedures developed November 2025 • Quarterly training sessions January, April, July and October 2026 • New user training April 2026 • New sole-source template developed and deployed July 2026 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: Corrective action to address internal controls and noncompliance was implemented as of November 2025. Management continues to implement best practices in procurement, including the procedures mentioned above.

Federal Agency Name: Department of Treasury Pass-through Agency: State of Indiana Office of Community and Rural Affairs Assistance Listing Number: 21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified: • The Entity’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. • Four instances where the Entity did not follow the procurement process and did not have any formal documentation in place with vendors. • Four instances where the Entity entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Responsible Individuals: Sara Morris, Chief Financial Officer and Jay Watkins, Sr. Vice President of Broadband Services Corrective Action Plan: Management will update their procurement policy to ensure it includes all required elements in accordance with Uniform Guidance. In addition, management will implement procedures and control processes related to the review of procurement to ensure the procurement methods are being followed and documentation isretained to support compliance. Management will also ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into a procurement transaction. Anticipated Completion Date: October 2026

Action taken in response to finding: The Commission is in the process of adopting an updated procurement and conflict of interest policy to comply with compliance requirements.

The East Alabama Health Care Authority (the Authority) recognizes the importance of being sufficiently knowledgeable on federal grant requirements. Management acknowledges that while the Authority did complete procurement procedures in compliance with the grant requirements that it did not establish formal written policies and procedures addressing procurement methods, competition requirements, and documentations standards to be consistently applied to all procurement transactions under federal awards. To ensure compliance with federal grant awards moving forward, the Authority will document policies regarding unmet requirements described above. Management will ensure that procedures to meet these policies are implemented and that evidence of this implementation is recorded. Contact Person & Proposed Completion Date Contact person responsible for corrective action: Dennis Thrasher VP - Controller (334) 528-2104 Proposed date of completion: 9/30/2026

Finding 2025-002 – Significant Deficiency Award No.: 21.027 Federal Grantor: U.S. Department of Treasury, Passed-through the County of Butte, Pass-through Grantor’s Number X25534. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The Agency’s procurement policy does not adequately document procurement requirements under the Uniform Guidance or contract provisions under Appendix II to Part 200 of the Uniform Guidance. Criteria: Uniform Guidance, Section 200.318(a) indicates “the recipient or subrecipient must maintain and use documenting procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327”. Required contracting provisions are documented in Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Cause: The Agency’s procurement policy needs to be updated to document the requirements of the Uniform Guidance. Effect: The Agency’s procurement policy does not comply with the requirements of the Uniform Guidance, which could result in procurements that do not comply with the Uniform Guidance and the awarding agency disallowing the federal award and requesting the return of the award. Context: The Agency’s procurement policy complies with many requirements of the Uniform Guidance, but the policy does not comply with certain required provisions, including the thresholds for micro purchases, simplified acquisition threshold and full public procurements and the requirements for sole sourcing procurements under section 200.320. The procurements tested were found to comply with procurement requirements under Uniform Guidance even though the policy did not include all of the required provisions. Recommendation: The Agency should update its procurement policy to reference Uniform Guidance §§ 200.317 through 200.327 and should reference contracting provisions under Appendix II to Part 200 to be in compliance with Uniform Guidance prior to procurements being made under future federal awards. Views of Responsible Officials and Planned Corrective Actions: The procurement policy will be updated to include procurement guidance under Uniform Guidance §§ 200.317 through 200.327 and contracting provisions under Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Title of Responsible Party: Finance Manager Implementation Date: By September 22, 2026

Finding 2025-003: Inadequate Procurement Documentation Management’s response: Concur Responsible individual: Finance Manager, Executive Director, Board of Directors Anticipated completion date: March 31, 2026 Management agrees with this finding and will implement the following: • Update procurement policies and procedures to align with 2 CFR 200, including: o Develop and implement standardized procurement checklists o Require cost/price analysis for all qualified transactions o Require suspension/debarment checks for all qualified transactions o Require supervisory review and oversight by Board of Directors o Require adherence to document retention and destruction policy

FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.

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.