Corrective Action Plans

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.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement: For two vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the Procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Suspension and Debarment: Two vendors were identified for which the School Corporation was required to verify the suspension and debarment status, however no such verification could be provided for audit. Contact Person Responsible for Corrective Action: Food Service Director, Joshua Deck Contact Phone Number and Email Address: (812) 649-2591 / josh.deck@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: Effective FY 2025/2026

FINDING 2025-001 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Samantha Berrier Contact Phone Number and Email Address: 219-962-2909, sberrier@rfcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The offices of the Northwest Indiana Special Education Cooperative (NISEC), on behalf of River Forest Community School Corporation, its member school, has implemented a corrective action plan to ensure that the proper methodology for procurement is followed. Additionally, a system of internal controls has been established to ensure that vendors are procured using the required methods. The Northwest Indiana Special Education Cooperative created a corrective action plan to develop procedures to obtain bids when any vendor will exceed the simplified acquisition threshold. As part of this corrective action plan they have included procedures to follow if a noncompetitive procurement would be applicable. These procedures include documenting the rationale for using this alternative method and requesting approval from the Board of School Trustees when doing so. Anticipated Completion Date: October 9th, 2024

Audit Finding 2025-001 - Procurement and Suspension and Debarment Corrective Action Plan The City will revise its procurement policy and procedures to address all relevant requirements under Uniform Guidance, specifically: . Incorporate written standards of conduct covering conflicts of interest for employees involved in procurement, in accordance with 2 CFR 200.318(c)(1). . Include written policies and procedures requiring affirmative steps to solicit and consider participation by small, minority, women-owned, veteran-owned, and labor surplus area businesses, as specified in 2 CFR 200.321(b). . Add explicit provisions to require sufficient and detailed recordkeeping for all procurement transactions funded with federal awards, addressing the requirements of 2 CFR 200.318(i). Persons responsible for corrective action Jamie Rhodes, Administrative Services Manager Branden Dross, City Administrator Corrective action completion date June 30, 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Missy Schultheis Contact Phone Number and Email Address: 812-354-8478 mschultheis@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review and update the existing procurement policy to ensure it clearly outlines the procedures for different purchasing methods including the specific thresholds. We will establish a procedure requiring the retention of all documentation supporting procurement decisions. We will develop a process to verify that vendors/contractors are not suspended or debarred by any federal or state agency prior to entering into a "covered transaction" or contract. Anticipated Completion Date: This be implemented in the 2025-2026 school year and will continue for future years.

CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact Person Responsible for Corrective Action: Meghan Butts, Executive Director Corrective Action: The Upper Valley Lake Sunapee Regional Planning Commission will take the following actions to address finding 2025-001: We will revise our existing procurement policy to align with the current requirements outlined in 2 CFR 200. Anticipated Completion Date: February 11th, 2026

The District Cafeteria Manager, Melanie Pardini, corrected this procedure for fiscal year 2025-26 and has the process in place going forward for each fiscal year.

Condition: The School District's internal controls did not effectively identify the required formal solicitation. The School District did not utilize the appropriate competitive procurement methods and did not retain suspended or debarred verification documentation. Planned Corrective Action: The School District will ensure that the proper procurement methods are adhered to, prior to executing future contracts. This includes also reviewing to ensure that vendors are not suspended or debarred, prior to awarding the contract. To accomplish this, the School District will use their grant budget process as a control for identifying the population of applicable expenditures that will be subject to procurement compliance requirements for federal programs. Contact person responsible for corrective action: Kyle Jen, Chief Financial and Operations Officer Anticipated Completion Date: 6/30/2026

Finding 2025-001 Lack of Internal Control Over Procurement Name of Contact: Rayna Bowdre Corrective Action: The District will ensure all procurements follow Board polices relating to bids and procurement, including written documentation for sole source and procurements and exemptions. Proposed Completion Date: December 31, 2025.

Condition: The School District's internal controls did not effectively identify all of the required components necessary in formal solicitation documents for food service/cost reimbursable contracts and when using a third party entity (e.g., consortium) and did not utilize competitive procurement methods. Planned Corrective Action: The School District is revising its food service procurement documents to explicitly include all required contract provisions under the Uniform Guidance. The School District is also incorporating recent interpretations and guidance from the U.S. Department of Agriculture (USDA), as communicated through MDE, particularly regarding cooperative purchasing and pricing structures for federal compliance. These actions are intended to strengthen the procurement controls to ensure all future food service contracts meet the compliance requirements of the Uniform Guidance and USDA regulations. Contact person responsible for corrective action: Danielle Jacobs, Director of Business Services Anticipated Completion Date: 8/15/2025

We acknowledge the audit finding and agree that, for the two vendors identified, documentation of suspension and debarment verification was not completed or retained in accordance with proper internal controls for our federal programs. This was an oversight in our procurement documentation process and not an intentional omission. Neither vendor had any exclusions based on the SAM.gov database record. Since becoming aware of this issue, the organization is in the midst of implementing the following corrective actions to strengthen compliance with suspension and debarment requirements: (1) Revised Procurement Procedures- We will update our written procurement policies and procedures to explicitly require and document suspension and debarment checks prior to the execution of any contract using federal funds. This includes checking the federal SAM.gov database or obtaining a signed certification from the vendor, as permitted. (2) Standardized Documentation- We will create a standardized checklist that must be completed and filed in the procurement record for each vendor before payment of federal funds. This form documents the date, verification method, and staff member responsible. (3) Staff Training- All staff involved in procurement and accounts payable will complete training on federal procurement requirements, including suspension and debarment verification. This training will be repeated annually and upon onboarding of new staff. (4) Internal Control Review- A secondary review step has been added. Before any payment of federal funds is processed, our finance team will verify that the suspension and debarment check is on file. This dual review adds an additional layer of assurance.

We agree with auditor's comments, and the following actions have or will be taken to ensure the procurement of goods and services for the nutrition services department follows all applicable steps according to Title 2, Code of Federal Regulations (2 CFR) sections 200.317 -200.327; Title 7, Code of Federal Regulations (7 CFR), parts 210 and 220; and all applicable state and local rules: 1. During the school year 2024/2025, changes were made to staff to allow for additional oversight. A Procurement Specialist reporting directly to the Director of Purchasing was added to staff in lieu of a Buyer that had previously reported to the Director of Nutrition Services. This move allowed for an additional step to ensure proper procurement is happening. 2. All purchasing methods, including Micropurchase, Simplified Acquisition, and Formal, will be followed in accordance with all applicable regulations, in line with RUSD's written procurement procedures. 3. Any noncompetitive procurement will only occur if the conditions outlined in applicable regulations are met and sufficient evidence and documentation is received and retained, including participating in performing due diligence to ascertain whether a single source document is accurate from any given vendor. 4. In addition documented annual training will take place for all staff involved in the procurement process. This procedure includes a review and annual update of procurement procedures, if applicable, and an acknowledgement of the nutrition services code of conduct in regards to purchasing. Please reach out to us with any questions.

Management will update written procurement policy that conforms with the Uniform Guidance and implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Our HUD program currently checks certificates of occupancy through the City of Rochester and Towns to ensure that the properties do not have violations. Moving forward, we will also check new landlords and or contractors through the central contractor registry to be following federal requirements regarding suspension and debarment.

The College acknowledges the repeated finding and recognizes the need to strengthen internal controls and documentation procedures to ensure compliance with applicable federal procurement requirements and the RMI Procurement Code. During FY2025–FY2026, the College continued implementing corrective measures to improve procurement compliance and record retention. These efforts include the use of an upgraded cloud-based filing system to ensure proper documentation, organization, and accessibility of procurement records. The College has also strengthened oversight through the recruitment of additional Procurement and Accounts Payable personnel to improve compliance monitoring and accountability. The College continues to review and strengthen its procurement policies and procedures to ensure compliance with federal requirements, including proper vendor quotations, competitive procurement, sole-source justifications, documentation of vendor selection, and verification of suspension and debarment status. Additionally, periodic staff training and improved supervisory review will continue to reinforce compliance with procurement requirements. The College will also review the identified questioned costs and determine whether additional supporting documentation or corrective actions are necessary. These ongoing efforts are intended to strengthen procurement compliance, improve accountability, and prevent recurrence of similar findings in future audits.

Audit Finding Number 2024-005 Audit Finding Title Procurement and Suspension and Debarment Planned Corrective Action Effective September 2026, procedures were put in place for each subgrantee or anyone being paid over $25,000 using federal funds to complete an attestation and submit their internal or audited financials before we contract with them. This will ensure that they have the financial ability to carry out the agreed upon work. We also perform our own verification of their suspension and debarment status. Their Year 4 contracts include a certification that they have not been suspended or debarred and that they are required to inform us if that status changes. We are also in the process of implementing a procurement policy related to federal funding. This policy will be fully implemented by December 2026. Name(s) and title(s) of contact person(s) responsible for corrective action Kim Cockerham, Sr. Director of Finance and Accounting Michelle Swittenberg, EVP of Enterprise Operations

Views of Responsible Officials: The Town and School Department respectfully disagree with the conclusion that sufficient procurement documentation was not maintained for the project identified in the finding. The project referenced was a renovation of the culinary classroom at Carver Middle High School, a portion of which was funded using ARPA resources. The School Department followed a traditional design-bid-build procurement process and believes the project was conducted in full compliance with the applicable requirements of M.G.L. Chapter 149. Subsequent to the issuance of the draft finding, the School Business Office confirmed that comprehensive procurement records are maintained for this project, including: • Designer procurement and RFQ documentation; • Advertising and public posting records; • Invitations for Bids (IFB); • Filed sub-bid documentation; • Bid tabulations and award records; • Executed contracts; • Required bonds, certifications, and contract compliance documentation; and • Other supporting procurement materials. The School Department maintains both electronic and original hard-copy records for the project and has indicated that these materials are available for review. The Town understands that not all documentation may have been requested from, or reviewed with, School Department personnel during the audit process. Corrective Action Plan While management believes the procurement process complied with statutory requirements, the Town recognizes the importance of ensuring that all supporting records are readily accessible during future audits. To strengthen communication and documentation retrieval procedures, the Town will: 1. Establish a formal process for coordinating audit requests with all departments, including the School Department; 2. Maintain centralized tracking of procurement and grant-funded project documentation; 3. Ensure that supporting records maintained at the departmental level are identified and made available during future audit examinations; and 4. Continue training personnel on documentation retention requirements for construction and grant-funded projects. Management believes these steps will improve the efficiency of future audits while continuing to ensure compliance with all applicable procurement laws and regulations.

Corrective action taken On June 2, 2025, the Board approved revised Policy F2.01 v.01, Procurement for Product or Services, which requires competitive proposals for contracted services, documented selection criteria, and retention of bid responses and award decisions. Effective September 1, 2026, C-WHO adopted Procedure SOP F2.01 v.01, Procurement Under Federal Awards, approved by the Chief Executive Officer and the Director of Finance. The procedure supplements Policy F2.01 v.01 and applies to any purchase charged in whole or in part to a federal award. SOP F2.01 v.01: • incorporates 2 CFR 200.317 through 200.327 and Appendix II to Part 200, as adopted by HHS at 2 CFR Part 300; • sets procurement methods by the current federal thresholds (micro-purchase, small purchase with at least three written quotes, and sealed bids or publicized proposals above the simplified acquisition threshold); • limits noncompetitive procurement to the circumstances in 2 CFR 200.320(c), documented on a Sole Source Justification form approved before commitment; • requires SAM.gov exclusion verification before any covered transaction of $25,000 or more (2 CFR Part 180), and an LEIE check for health care service providers; • establishes written conflict-of-interest standards, including disclosure, recusal, and disinterested Board approval for related-party procurements; • requires cost or price analysis above the simplified acquisition threshold and documented price reasonableness for all federally funded purchases; • requires a Federal Procurement Checklist, completed by a preparer and signed by a separate reviewer, before a contract is signed, a purchase order is issued, or federal funds are charged; and • credits discounts and rebates on federally funded purchases to the award under 2 CFR 200.406.

The Institute will adopt written procurement policies and procedures that conform to the Uniform Guidance procurement standards, present them to the Board of Directors for approval, and train the personnel responsible for procurement on their use. Anticipated completion date: December 31, 2026. Responsible contact person: Kathy Walker, Executive Director.

Management agrees with the finding. Management has downloaded 2 CFR Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

Person responsible for corrective action plan: Stacey Mike, Interim Tribal Chair Marjianne Yonge, Tribal Treasurer PO Box 747 Lone Pine, CA 93545 (760) 876-1037 Condition: During testing, we noted the following: 21.027 • 5 of 6 IIIs did not have documentation of alternate bidding or sole source justification. • 6 of 6 IIIs did not have documentation that a suspension and debarment search was performed prior to purchasing. 93.445 • 7 of 7 IIIs did not have documentation that a suspension and debarment search was performed prior to purchasing. Corrective Action: Suspension and debarment procedures will be documented by the fiscal staff prior to paying any new contractors. Bidding and or sole source justification shall be documented and provided to the fiscal staff prior to the payment being issued. Anticipated date of completion: November 30, 2026.

2024-005 - LACK OF SUPPORT FOR PROCUREMENT-ALN 12.118 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: The City of Cando did not maintain support surrounding the selection process for the construction engineer for the 2022 Water and Improvements project. Therefore, we were unable to determine if the engineer selection was properly completed. In addition, the City of Cando did not have a procurement policy. Management's Response: We Agree. The City will ensure future procurement documentation for construction engineering services is maintained. Anticipated Completion Date: 2026

Condition 1: The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remain in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2, #1: Except for items #1, #5, #6, #7, #8 & #9, the Ministry of Finance agrees with the finding and will ensure that vendor selection and the justification for the selected vendor are clearly documented in BRVs and TMV to demonstrate compliance with procurement requirements. Condition 2, #2: The Ministry agrees with the finding. Competitive bidding should be undertaken when a multi-year contract expires. Condition 3: At the start of a new fiscal year, the MOF Compliance team will perform an annual screening of all Funder/Client (Supplier) in Bisan against the SAM.gov list of debarred/suspended entities.

Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remained in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2. Except for items #1 & #8, the Ministry of Finance agrees with the finding and will ensure that vendor selection and the justification for the selected vendor are clearly documented in all TMVs and BRVs to demonstrate compliance with procurement requirements. Condition 3. Same response as Finding No.: 2024-014 - Condition 3

Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remained in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2-1. Items 1-2,7 The Ministry disagrees with the findings. All three purchase orders were supported by the required documentation at the time of review and prior to the issuance of the purchase orders. Items 3-6 The Ministry intends to revisit the existing travel policy and update accordingly. Item 8 The vendor was directly selected as the authorized distributor & service provider for medical equipment & supplies in the Marshall Islands. Going forward, the Ministry will ensure a signed justification letter from the Head of Department is attached to support sole-source procurements. Item 9 The Ministry will return requisitions with insufficient supporting documentation and will conduct a procurement training in October 2026 to reinforce procurement requirements. Condition 2-2 Item 1 The Ministry now requires a Request for Quotation (RFQ) form to be submitted as evidence of compliance with competitive procurement requirements. Items 2-3 The Ministry disagrees with the findings. Supporting documentations can be found on PR 23/00023360 (#2) & PR 23/00001990 (#3) Item 4 Effective in FY2025, the Enewetak/Ujelang Local Government operations were transferred to the Ministry of Finance. As a result, all procurement activities are now processed through the Ministry and are required to comply with the applicable procurement code, established regulations, and the Ministry's internal procurement policies and procedures, thereby strengthening oversight and ensuring compliance. Condition 2-3 1-7 The Ministry now requires a Request for Quotation (RFQ) form to be submitted as evidence of compliance with competitive procurement requirements 8 The Ministry of Finance will require that the PSS Hot Lunch Vendor selection Report (endorsed by the Bid Committee) be submitted with the initial payment to the Hot Lunch Vendors. 9 Once the DLS contract expires, it will be advertised for competitive bidding. Condition 3 At the start of a new fiscal year, the MOF Compliance team will perform an annual screening of all Funder/Client (Supplier) in Bisan against the SAM.gov list of debarred/suspended entities.

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.