Corrective Action Plans

Condition During our testing, we noted that the Educational Foundation's written procurement policy did not incorporate all applicable Uniform Guidance procurement requirements. Specifically, the policy did not adequately address procurement methods and dollar thresholds, suspension and debarment verification, and required contract provisions. As a result, the Association's written policy was not fully consistent with the requirements of 2 CFR Part 200 Corrective Action Plan Corrective Action Planned: Management acknowledges the auditor's recommendation regarding the enhancement of the Association's procurement policies to ensure full compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §§ 200.317–200.327). LeadingAge Michigan has initiated a comprehensive review of its existing procurement policies and procedures to ensure they fully incorporate all applicable federal procurement requirements. The revised policy will include provisions addressing procurement methods based on established dollar thresholds, competition requirements, documentation and record retention standards, contractor responsibility determinations, suspension and debarment verification, conflict of interest requirements, and all required federal contract provisions applicable to federally funded awards. Management will also establish standardized procurement documentation and review procedures to promote consistent application of the policy and to ensure compliance is adequately documented for all applicable purchases funded through federal awards. In addition, personnel responsible for procurement and grant administration will receive training on the updated procurement policy and the requirements of 2 CFR Part 200. This training will emphasize proper procurement planning, documentation, competitive purchasing requirements, and compliance with federal regulations to ensure consistent implementation throughout the organization. Management is committed to maintaining strong internal controls over federal awards and will periodically review procurement practices to ensure ongoing compliance with Uniform Guidance requirements. Name(s) of Contact Person(s) Responsible for Corrective Action: David Herbel, President and CEO Dalton Herbel, Vice President of Public Policy Kelly Price, Member Success Coordinator Anticipated Completion Date: 9/30/2026

Finding Number 2024-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The Office of Management and Enterprise Services (OMES), Central Purchasing Division, respectfully submits this response regarding the use of federal funds in connection with statewide contracts established through the Rolling Request for Proposal (RFP) pilot program. Since the audit period, OMES has implemented significant enhancements to its statewide contracting processes to further strengthen documentation, oversight, and compliance with both state procurement law and Uniform Guidance. These enhancements also address the recommendations identified in this finding. Compliance with Uniform Guidance (2 CFR Part 200) OMES affirms that procurements conducted under the Rolling RFP pilot program were performed in accordance with applicable provisions of Uniform Guidance and the Oklahoma Central Purchasing Act, including but not limited to 2 CFR §§ 200.317, 200.318, and 200.404. Pursuant to 2 CFR §200.317, OMES follows the same procurement policies and procedures for federal funds as are used for non-federal funds. The Rolling RFP model did not eliminate competitive procurement. Rather, it modified the timing of vendor qualification by allowing qualified vendors to compete for inclusion on the statewide contract throughout the open solicitation period while agencies continued to conduct project specific Statements of Work under those contracts. Consistent with 2 CFR §200.318(a), OMES maintains oversight to ensure that procurements are conducted in a manner providing full and open competition, and that contractors perform in accordance with the terms, conditions, and specifications of their contracts. The Rolling RFP model increased vendor participation and competition by allowing qualified suppliers to submit responses on a continuous basis, thereby expanding the competitive pool available to agencies. Further, in accordance with 2 CFR §200.404, OMES ensures that costs are reasonable by requiring evaluation of pricing at both the contract award level and the transaction level. Vendors are vetted through a formal evaluation process, and Statements of Work (SOWs) are developed with agency and subject matter expert involvement to confirm that pricing reflects what a prudent person would incur under similar circumstances. Vendor pricing remained subject to procurement review, agency evaluation, statement-of-work negotiations, market comparisons, procurement approval processes, and applicable fair and reasonable price determinations required under state procurement law and Uniform Guidance. Additionally, OMES Central Purchasing operates under formalized internal procedures, including its Framework Agreement Creation Standard Operating Procedure, which explicitly requires adherence to Uniform Guidance. The SOP mandates vendor vetting, competitive evaluation, including the contract clauses required by 2 CFR §200.327 and Appendix II to Part 200, and documented evaluation methodologies to ensure transparency, consistency, and compliance in all framework (statewide) agreements. In addition, OMES has adopted the first-ever Oklahoma Procurement Manual, which establishes standardized statewide guidance for procurement planning, contract administration, federal grant compliance, documentation standards, and competition requirements. The manual reinforces Uniform Guidance requirements and provides agencies with consistent statewide procurement procedures for acquisitions involving both state and federal funds. Program Structure and Administrative Considerations The Rolling RFP pilot program functioned as a framework agreement structure, wherein suppliers were pre-qualified through a competitive solicitation process and agencies subsequently issued project-specific Statements of Work. This approach was designed to align with allowable procurement methods under Uniform Guidance. OMES recognizes, however, that the continuous open nature of the solicitation created administrative challenges and increased complexity in maintaining consistent documentation and oversight as vendor participation scaled. Documentation and Administrative Enhancements Although the pilot program did not have a standalone written procedure specific to Rolling RFPs during the audit period, it operated under existing procurement statutes, standardized solicitation procedures, evaluation documentation, internal operating procedures, and statewide contract templates. Documentation practices have since been further standardized and consolidated. While the program operated under existing procurement statutes, solicitation procedures, evaluation documentation, and internal operating practices, OMES has since implemented additional written procedures, standardized documentation requirements, and centralized guidance to improve consistency, transparency, and ease of audit review. These enhancements strengthen an already competitive procurement process by providing more comprehensive documentation of procurement decisions and contract administration. Program Closeout Following a comprehensive review, the State Purchasing Director formally determined that the Rolling RFP pilot program would be closed effective July 1, 2024. All resulting contracts have transitioned to standard statewide contract structures, which incorporate defined solicitation periods and controlled opportunities for vendor participation through supplemental solicitations. Because the pilot program has been discontinued and replaced with traditional statewide contracting methods, legislative recommendations regarding continuation of the pilot are no longer necessary. Remedial Actions Aligned to Uniform Guidance In response to audit observations and in furtherance of compliance with Uniform Guidance, OMES is implementing the following corrective actions: 1. Enhanced Competition at the Transaction Level (2 CFR §200.319) For all service-based procurements utilizing statewide contracts, agencies will be required to conduct a documented second level of competition (e.g., multiple quotes, mini-bids, or competitive SOW processes) to ensure full and open competition at the task/order level. 2. Structured Re-Competition of Vendor Pools OMES will replace continuously open solicitations with time-bound supplemental RFPs, ensuring periodic recompetition and maintaining a manageable and auditable procurement environment. 3. Strengthened Cost Analysis and Documentation (2 CFR §200.324) OMES will reinforce requirements for price analysis and cost reasonableness determinations at both the contract and transaction levels, with enhanced documentation standards to support audit review. 4. Formalized Policies and Procedures (2 CFR §200.318(a)) OMES Central Purchasing is dedicated to documenting all procurement processes, particularly those impacting purchases using federal funds. This includes comprehensive SOPs, required contract attachments (including federal terms), and standardized evaluation and recordkeeping practices. Specifically, we have created SOPs for pilot programs and for statewide contracts generally. While comprehensive written procedures specific to the Rolling RFP pilot program had not yet been consolidated into a standalone procedure during the audit period, the program operated under existing procurement statutes, statewide solicitation procedures, evaluation documentation, internal operating procedures, and standardized contract documents. OMES has also implemented standardized procurement templates and required federal contract attachments that incorporate the clauses required under 2 CFR §200.327 and Appendix II to Part 200. These standardized documents promote consistent compliance across procurements utilizing federal funds. 5. Statewide Procurement Manual OMES has recently released the first-ever Oklahoma Procurement Manual, which provides statewide guidance to agencies and includes a dedicated section on federal grant compliance. The manual reinforces Uniform Guidance requirements, including competition, cost reasonableness, and documentation standards. 6. Ongoing Oversight and Training OMES will continue to provide training, procurement memoranda, and guidance to agencies to ensure consistent understanding and application of federal requirements, while reinforcing that subrecipients are responsible for compliance with the specific terms of their federal awards. Anticipated Completion Date Sine Die Responsible Contact Person Amanda Otis, State Purchasing Director for the State of Oklahoma

Finding Number 2024-075 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Office of Management and Enterprise Services – Grants Management Office Response: OMES-GMO respectfully disagrees with several conclusions contained in this finding. The finding concludes that the transfer of CSLFRF funds to the twenty-two (22) state agencies does not create a subrecipient relationship because OMES and the agencies are part of the same State of Oklahoma Single Audit. OMESGMO respectfully disagrees with this conclusion. Pursuant to 62 O.S. § 255.1, “The Legislature authorizes the Office of Management and Enterprise Services to manage federal APRA funds by requiring all receiving entities known as subrecipients to sign a grant agreement. Any entity, without exception, including state agencies receiving an appropriation from the Statewide Recovery Fund or a similar fund with federal requirement attached to its use shall have a fully executed grant agreement in place within sixty (60) days after enactment of any legislation that appropriates funding from the Statewide Recovery Fund of the State Treasury created in Section 1, Chapter 319, O.S.L. 2022, and be in compliance with such agreement before a disbursement can be made.” Under this statutory framework, each agency enters into a Grant Agreement with OMES and is subject to grant-specific terms and conditions, reporting requirements, monitoring, and ongoing oversight. Accordingly, OMES has administered the CSLFRF grant in accordance with state law and consistent with its responsibilities as the State's designated pass-through entity since the inception of the program. The authorization from the Oklahoma State Legislature has provided for a much more extensive oversight of the state entity subrecipients than would exist if OMES followed the model suggested by SAI, as OMES would not be subject to the subrecipient monitoring Federal regulation under 2 CFR § 200.332, for these state entities. By following the state law passed by the Legislature, OMES monitors each state entity subrecipient, and in turn, has signed a grant agreement with these state entity subrecipients that requires them to do the same for any of their subrecipients that are administering projects set out specifically by the State Legislature through appropriation bills. OMES requests SAI to revisit the position that these state entities are not OMES’ subrecipients and consider the implications that if OMES were to treat the state entities as non-subrecipients, OMES would be in direct defiance of state law. OMES-GMO also disagrees with the conclusion that sufficient supporting documentation was unavailable for several of the transactions identified in this finding. OMESGMO is committed to strong documentation standards, reimbursement review procedures, and project oversight to ensure continued compliance with applicable federal and state requirements. Despite OMES-GMO’s request to be included in audit communication with the state entities, SAI’s documentation requests for the sampled expenditures were directed primarily to the individual agencies. Several agencies experienced staffing changes during the audit period, resulting in inconsistencies in responding to documentation requests and, in some instances, uncertainty regarding the specific information being requested by the auditors. In multiple cases, the supporting documentation ultimately existed and was available but was either maintained by OMES-GMO or inadvertently omitted from the agency's initial submission. If OMES-GMO was afforded the opportunity to submit or explain documentation maintained by its office before the finding was finalized, both the administering agency and OMES-GMO would have been able to provide a more complete record for evaluation and may have altered the conclusions reached for certain transactions. OMES-GMO has had recent conversations with SAI regarding this issue, and are encouraged by the willingness of SAI to be open to working with OMES-GMO to facilitate a different process for future audits that involves a coordinated with both the administering agency and OMES-GMO so that auditors have access to the complete record before audit conclusions are finalized. Agency Responses: Agency 025 – Oklahoma Military Department (OMD) OMD partially concurs with the finding regarding the level of supporting documentation submitted with the vendor's invoices for payment. However, the construction contracts in question were executed using Guaranteed Maximum Price (GMP) contract structures. Under these contracts, the contractor is responsible for maintaining all subcontractor invoices, material invoices, and supporting financial records associated with each progress payment. The contracts require these records to be retained for the applicable record retention period and made available for review by the agency, State, or federal government upon request. Agency 085 – Oklahoma Broadband Office (OBO) Broadband Mapping / Cross-Grant Expenditures The Oklahoma Broadband Office (OBO) requests the transactional detail associated with these findings to allow the agency to fully evaluate the questioned transactions. While OBO agrees that expenditures must be charged to the appropriate federal funding source and class fund, the office respectfully disagrees that the questioned expenditures represented unallowable supplementation of other federal awards. The contracts included shared deliverables necessary to complete the CSLFRF Broadband Mapping project. During contract administration, OBO identified billing discrepancies involving work performed under multiple grant programs. Following approximately eleven months of negotiations, OBO entered into a settlement agreement with the contractor that limited payment to services actually received and excluded services that were not performed. The resulting payments represented services provided under multiple funding sources and were processed together to accurately reflect work completed during FY2024. Procurement Finding – Lee Consulting Contract OBO concurs with the finding that services began prior to the execution of a purchase order for the April 2023 services. Upon identifying the issue, OBO completed the required ABS Form 009 Ratification Agreement to formally document the procurement exception and properly authorize payment. To prevent future occurrences, OBO has: • Hired a full-time General Counsel to oversee contract administration and procurement compliance. • Implemented a policy prohibiting execution of contracts or commencement of work until a purchase order has been fully approved and funds have been encumbered. • Provided procurement training to management and staff regarding Oklahoma encumbrance requirements. Agency 400 – Office of Juvenile Affairs (OJA) OJA partially concurs with the finding. The agency believes the purchase of a Keurig coffee maker and heater towers by Western Plains falls within the approved project scope for the purchase and installation of furniture, fixtures, and equipment. However, OJA acknowledges that decorative wall art purchased by Youth and Family Services of Hughes and Seminole Counties does not appear to fall within the approved project scope. Agency 452 – Oklahoma Department of Mental Health and Substance Abuse Services (ODMHSAS) ODMHSAS acknowledges the documentation and procurement concerns identified in the finding. Specifically, the agency recognizes that certain invoices lacked sufficient detail describing services performed and that one expenditure required ratification because services were obligated prior to encumbering funds. ODMHSAS agrees that federally funded expenditures should be supported by documentation demonstrating the services performed, the project purpose, and the relationship to the approved scope of work. ODMHSAS also agrees that obligations should not be incurred before a valid purchase order and encumbrance have been established. Agency 619 – Oklahoma Health Care Workers Training Commission (HWTC) During the period associated with the questioned expenditure, the Care Providers program submitted a significant volume of supporting documentation with each reimbursement request, often consisting of 500 to 1,000 pages transmitted through multiple emails over several days. In some instances, the documentation was not organized sequentially, making it difficult to efficiently compile and review the complete reimbursement package. As staff assembled documentation received through multiple transmissions, a portion of the supporting documentation was inadvertently omitted from the reimbursement file maintained by the agency. Consequently, the complete documentation package was not included in the materials submitted to OMES-GMO with the reimbursement request. To address this issue, management revised its documentation review procedures. Rather than requiring agency staff to reorganize incomplete or disorganized submissions, staff are now instructed to return reimbursement packages that are incomplete or not properly organized and require the submitting entity to provide a revised, complete documentation package. This change places responsibility for maintaining complete supporting documentation with the originating entity and has resulted in more organized reimbursement submissions while reducing the risk of incomplete supporting records. Agency 830 – Oklahoma Department of Human Services (DHS) DHS disagrees that the questioned incentive gift cards were outside the approved project scope. The PCCT Fatherhood Today program is designed to strengthen father-parent-child relationships by engaging fathers through education, support services, and community resources. The program targets fathers residing in underserved communities who often face barriers to participation, including transportation, childcare, financial hardship, and food insecurity. The $100 gift cards are provided only after participants successfully complete the twelve-week 24/7 Dad curriculum. The gift cards serve as an incentive to recruit and retain participants and support the program's objective of increasing father engagement. DHS believes the incentives directly support successful program participation and allow participants to obtain essential household items for their families. DHS further noted that participant outcomes are measured through pre- and post-program assessments demonstrating increased knowledge and engagement among participating fathers. Gift cards are purchased using agency purchasing procedures, maintained in secured storage, and distributed only upon successful completion of all program requirements with appropriate documentation maintained for each recipient Anticipated Completion Date OMES: December 31, 2026 025: Completed 085: Completed 400: Completed 452: December 31, 2026 619: December 31, 2026 830: Completed Responsible Contact Person OMES: Elizabeth Base 025: Angela Tackett 085: Beverlee Harbuck 400: Kevin Haddock 452: Chad Carden 619: Kami Fullingim 830: Lindsey Kanaly

Finding Number 2024-043 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Office of Management Enterprise Services – Grant Management Office Response: The Oklahoma Office of Management and Enterprise Services (OMES) agrees that strong project planning and feasibility evaluations for large-scale capital projects are important processes for each individual agency to implement. OMES also recognizes that certain factors can impact the original evaluation, and if those factors occur, reevaluation of a project’s feasibility is a prudent measure to determine the future direction of a project. The Federal regulation 2 CFR § 200.317, directs that “a State must follow the same policies and procedures it uses for procurements from its non-Federal funds.” Oklahoma has laws in place for state agencies for the purchase of tangible and intangible property, which ensure obligations are properly encumbered by a contract or purchase order. Therefore, OMES agrees that in order to be in compliance with federal and state laws and regulations, each individual agency should have strong internal controls in place to ensure obligations of federal funds are properly encumbered before commitments are made. ODMHSAS Response to Finding No. 2024-043 ODMHSAS partially concurs with Finding No. 2024-043. ODMHSAS agrees that controls should be strengthened for large-scale federally funded capital projects and acknowledges the separate encumbrance issue identified in the finding. ODMHSAS does not concede that the full $6,218,295 questioned amount was wasted, unallowable, or subject to repayment based solely on the later cancellation of the original Donahue new-build project. ODMHSAS acknowledges that the original Donahue Behavioral Health Campus new-build project did not proceed to construction and that the Department later pursued a different facility solution through acquisition and renovation of an existing facility. The Donahue project, however, was an active, legislatively funded capital project intended to replace Griffin Memorial Hospital at the time the expenditures were incurred. Based on the available expenditure detail, the questioned-cost population includes architectural services, site or lease-related payments, consulting services, surveying or mapping services, and other planning and development costs associated with the project. ODMHSAS recognizes that the original project did not result in a completed capital asset. ODMHSAS also recognizes that federal allowability requires more than the existence of an approved project. Costs must be necessary, reasonable, allocable, and adequately documented. For that reason, ODMHSAS will conduct a reasonable transaction-level review using available records to determine what documentation exists for the expenditures identified in this finding, what work was performed, whether any deliverable or work product was received, whether the expenditure provided planning, feasibility, decision-making, or other project value, and whether further coordination with OMESGMO is needed regarding accounting treatment or other resolution. ODMHSAS further notes that the decision to discontinue the original Donahue new-build project should not, by itself, determine whether every planning or development cost incurred before cancellation was wasted or unallowable. ODMHSAS did not pay for a completed building at that stage of the project; it paid for planning, design, cost-estimating, site-evaluation, and feasibility-related services for an authorized replacement hospital project. The SLFRF capitalexpenditure framework recognizes that recipients may evaluate the need addressed, the appropriateness of a capital expenditure, and alternative capital approaches before determining the best path forward. Available information indicates the original concept contemplated moving both Griffin Memorial Hospital and CRC functions to the Donahue site, and the project scope, bed count, and estimated cost were later reevaluated as construction costs increased significantly, including post-COVID construction-cost escalation. Those services produced project information, design materials, cost information, and feasibility analysis that provided decision-making value, including information that helped ODMHSAS determine that the original newbuild approach was not financially feasible and that an alternative facility solution was necessary before substantially greater construction costs were incurred. ODMHSAS will therefore review the expenditures by category and transaction rather than treating the later cancellation of the project as dispositive of the allowability or value of each prior cost. ODMHSAS also notes the timing of the legislative and project changes. On October 5, 2022, the Legislature appropriated $87 million through HB 1013 for construction of a replacement facility for Griffin Memorial Hospital. During SFY 2024, ODMHSAS incurred planning, design, and initial development expenditures for the Donahue Behavioral Health Campus. The original new-build approach later became financially infeasible due to escalating construction costs and budget shortfalls, and by May 2025 ODMHSAS had moved away from the original construction plan and pursued acquisition and renovation of the former SSM Health facility as the successor facility solution. SB 1178 then reappropriated and redesignated $66.5 million of the original $87 million appropriation from construction of a replacement facility for Griffin Memorial Hospital to purchase and renovation of a replacement facility for Griffin Memorial Hospital, within the same thirty (30) mile geographic limitation. SB 1178 also recognized that the original appropriation could be reduced by prior expenditures, encumbrances, and transfers. ODMHSAS does not contend that SB 1178 alone resolves the allowability of prior costs, but it is relevant context showing that the remaining project funding was redirected by legislative action for the same public-health purpose of replacing Griffin Memorial Hospital. ODMHSAS further notes that the successor SSM acquisition and renovation project continued the same underlying public health purpose as the original Donahue project: replacing Griffin Memorial Hospital and expanding behavioral health treatment capacity. Available SSM transaction documents reflect that ODMHSAS pursued the purchase of the property at 2129 S.W. 59th Street for use in addressing the ongoing demand for mental health services, and related lease documentation reflects that ARPA-SLFRF funds used for the lease were designated for behavioral health services expansion. After the original Donahue new-build approach was no longer financially viable, ODMHSAS pursued the SSM acquisition and renovation approach as a feasible alternative to continue the Griffin replacement purpose. ODMHSAS will also review whether any amounts included in the federal questioned-cost population were recovered, refunded, offset, corrected, or otherwise resolved after the original expenditure. Separately, ODMHSAS has identified Donahue-related refund activity associated with private donations and grants, including an Oklahoma State University refund of $4,822,671.93, donor refunds totaling $1,820,000, and a remaining balance of $3,002,671.93 as of March 26, 2026. Based on current information, ODMHSAS understands this activity to relate to private donations and grants, not CSLFRF/ARPA funds. ODMHSAS will review the underlying accounting records to confirm the funding source, deposit, refund, and remaining balance treatment, and to ensure that this private donation and grant activity is treated separately from the federal questioned-cost population. ODMHSAS has also identified local contribution activity within the questioned-cost population that requires further review. Based on initial internal review, approximately $2.5 million of the questioned-cost population appears to relate to Oklahoma County and City of Oklahoma City contributions associated with the Donahue project, including $1.5 million from Oklahoma County and $1 million from the City of Oklahoma City. ODMHSAS understands that the Oklahoma County amount was repaid in December 2025 and that the City of Oklahoma City amount remains associated with the successor OKCBHC/SSM project or related project accounting. ODMHSAS will review the underlying accounting records, funding-source documentation, refund records, and project accounting treatment to determine whether these local contribution amounts should remain in the federal questioned-cost population, should be treated separately, or should otherwise affect the questioned-cost amount. ODMHSAS acknowledges the separate encumbrance issue related to claim 629685. Based on available records, the claim involved an obligation for services that was incurred before the applicable purchase order and encumbrance process was completed, requiring a subsequent ratification. The Department recognizes that obligations should not be incurred before a valid purchase order and encumbrance are in place. As reflected in the finding, the $50,000 claim was corrected by payment with state funds and was not questioned. ODMHSAS will address that issue through strengthened pre-obligation controls, procurement review, and targeted guidance or training for staff responsible for initiating purchases or contracts. Nothing in this response should be construed as an admission that the full questioned-cost amount is unallowable or subject to repayment. ODMHSAS will coordinate with OMESGMO as needed after review of the available records, including any refund, recovery, offset, correction, or other accounting issue relevant to the questioned-cost population. Corrective Action Planned ODMHSAS will take reasonable steps to strengthen controls over planning, documentation, procurement, and encumbrance review for significant federally funded capital projects. ODMHSAS will develop or update internal review procedures for significant federally funded capital-project expenditures. The procedures will address project scope, available funding, estimated project cost, material changes in feasibility, and approval authority before substantial planning, design, development, or construction-related costs are incurred. The review process will be scaled to the size, complexity, and funding source of the project. ODMHSAS will also strengthen documentation expectations for federally funded capital project invoices. For future expenditures, invoices or supporting materials should identify the services performed, billing period, project phase, and connection to the approved project scope. Where invoices contain only general descriptions, such as “progress billing” or “work completed,” ODMHSAS will seek additional support from the vendor, project manager, or available project file before approving the cost for federal reimbursement. ODMHSAS will require program or project-level confirmation that services were received and were related to the approved project before payment or reimbursement is processed. Finance and Procurement will review federally funded capital-project expenditures for appropriate coding, available support, and compliance with applicable funding and encumbrance requirements. ODMHSAS will conduct a risk-based review of the Donahue expenditures identified in Finding No. 2024-043 using available records. The review will focus on identifying the vendor, amount, funding source, available support, and whether any cost was refunded, recovered, offset, corrected, or requires additional accounting review or coordination with OMES-GMO. Because many of the underlying project decisions and records predate current leadership and staff, ODMHSAS will conduct this review based on the documentation reasonably available to the Department. As part of that review, ODMHSAS will review available accounting and reporting records for the Donahue and SSM projects to determine how ARPA-SLFRF funds associated with the replacement-facility work were obligated, reported, redirected, or applied to the successor Griffin replacement facility project, and whether that treatment affects the federal questioned-cost population. ODMHSAS will separately review the Donahue-related private donation and grant refund activity, including the OSU-OKC settlement documentation, to confirm the funding source, deposit, refund, and remaining balance treatment, and to ensure that non-federal donation and grant activity is not included in, or confused with, the federal questioned-cost population. ODMHSAS will also review the Oklahoma County and City of Oklahoma City contribution amounts identified within the questioned-cost population, including documentation of the reported Oklahoma County repayment and the accounting treatment of the City of Oklahoma City contribution, to determine whether those amounts should remain in the federal questioned-cost population, should be treated separately, or otherwise affect the questioned-cost amount. To address the encumbrance concern, ODMHSAS will implement or reinforce a pre-obligation verification process for future procurements. Staff responsible for initiating purchases, contracts, task orders, or service authorizations will be directed to confirm that a valid purchase order and encumbrance are in place before authorizing work. Any transaction requiring ratification will be reviewed to determine the cause and whether additional corrective action is needed. ODMHSAS will provide targeted written guidance and, as needed, training to appropriate staff regarding federal documentation requirements, invoice review, project-scope review, funding-source verification, and state encumbrance requirements. Anticipated Completion Date ODMHSAS anticipates completing updated procedures, review checklists, and targeted written guidance by June 30, 2027. Because the Donahue review requires analysis of historical project expenditures, related accounting and reporting records, multiple funding sources, and coordination with OMESGMO, ODMHSAS anticipates completing the risk-based transaction review and related followup by December 31, 2027. Responsible Contact Person OMES: Elizabeth Base 452: Chad Carden

FINDING 2024-005 Finding Subject: Child Nutrition Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Formal procurement procedures have been established including micro-purchase and small purchase thresholds. Required price quotes are obtained and documented. Procurement history is maintained, including rationale and vendor selection. Vendor suspension and debarment checks are performed using SAM.gov or certifications. OPAA provides oversight of procurement processes and monitoring is ongoing. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance procurement control activities, and provide ongoing monitoring to ensure compliance with federal procurement standards, suspension and debarment requirements, and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook acknowledges the procurement deficiency identified in Finding 2024-001. The County previously developed and formally adopted a Federal Grant Procurement Policy on February 18, 2026, establishing procedures compliant with 2 CFR 200.317–327 and Appendix II, including required procurement methods, documentation standards, and inclusion of applicable federal contract provisions. The finding is reported as a repeat finding of prior years; however, the policy establishing these controls was adopted subsequent to the period in which the procurement activity under review occurred or during early implementation of the policy. As a result, the condition identified reflects a lapse in the consistent application of newly established procedures rather than a deficiency in policy design. To address this, the County has strengthened internal controls by requiring completion of standardized procurement checklists for all federally funded purchases and implementing enhanced supervisory review of procurement files to ensure that contracts and required federal provisions are included prior to execution and reimbursement. Additional guidance has been provided to staff to reinforce compliance expectations and ensure consistent application of procurement procedures. The County will continue to monitor procurement activities to ensure full implementation of established controls and anticipates that this finding will be resolved upon demonstration of consistent compliance in the subsequent audit period. Anticipated Completion Date: February 18, 2026 (Implemented)

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Dana L. Gendreau, Interim County Administrator Corrective Action: The County of Aroostook acknowledges the procurement deficiency identified in Finding 2024-001. The County previously developed and formally adopted a Federal Grant Procurement Policy on February 18, 2026, establishing procedures compliant with 2 CFR 200.317–327 and Appendix II, including required procurement methods, documentation standards, and inclusion of applicable federal contract provisions. The finding is reported as a repeat finding of prior years; however, the policy establishing these controls was adopted subsequent to the period in which the procurement activity under review occurred or during early implementation of the policy. As a result, the condition identified reflects a lapse in the consistent application of newly established procedures rather than a deficiency in policy design. To address this, the County has strengthened internal controls by requiring completion of standardized procurement checklists for all federally funded purchases and implementing enhanced supervisory review of procurement files to ensure that contracts and required federal provisions are included prior to execution and reimbursement. Additional guidance has been provided to staff to reinforce compliance expectations and ensure consistent application of procurement procedures. The County will continue to monitor procurement activities to ensure full implementation of established controls and anticipates that this finding will be resolved upon demonstration of consistent compliance in the subsequent audit period. Anticipated Completion Date: February 18, 2026 (Implemented)

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a model where the required contract, along with all necessary supporting documentation (specifically including bids, quotations, justification letters, and evaluation reports), must be attached directly to each invoice entry within the ERP system. This requirement ensures that a complete, centralized procurement file is retained and reviewed for compliance prior to any final disbursement.

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a model where the required contract, along with all necessary supporting documentation (specifically including bids, quotations, justification letters, and evaluation reports), must be attached directly to each invoice entry within the ERP system. This requirement ensures that a complete, centralized procurement file is retained and reviewed for compliance prior to any final disbursement.

DPNR with the support of the federal agency’s consultant will implement a centralized electronic repository system to serve as the official recordkeeping location for all procurement requests and supporting documentation. This repository will house all documents necessary to substantiate is a vendor is valid or debarred, including but not limited to: • A complete procurement listing for each fiscal year, including all procurements funded by Federal awards; • Documentation of suspension and debarment verification; • Vendor certifications and required Federal assurances; and • Any additional supporting documentation required under Federal regulations and DPNR procurement policies.

DPP has transitioned the Government of the Virgin Islands to a centralized eProcurement system, GVIBuy. Vendor profiles are centralized with all corporate documents attached. Additionally, DPP has published written guidelines that dictate adherence to federal regulations relate to the procurement of goods and services including records retention.

The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) for the CTE Center. Therefore, we were unable to determine if the CMAR selection was properly completed. In addition, Willison Basin Public School did not have a procurement policy. Management’s Response: We agree. The District will work to ensure that future projects are properly procured within state law and federal guidelines. Anticipated Completion Date: FY 2025

Develop procurement policy for federal grants noting that bids on federal grants will be advertised for at least three weeks.

FINDING 2024-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Anticipated Completion Date: December 2026

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 Department should review and enhance its procedures to ensure that it follows its procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased for the program. Response: The Department concurs with the finding and the need to strengthen controls to ensure the procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased are followed. Prior to the conclusion of the audit, the agency went live with its new procurement system, OpenGov in March 2025. OpenGov ensures that services are procured following policy and regulations. Corrective Action: The Department will ensure procurement rules and regulations are followed by enforcing the use of OpenGov throughout the agency. Name of the contact person responsible for the corrective action: Dorthy Young Anticipated date for completion of corrective action: July 1, 2026

The Department should review and enhance its procedures to ensure that it follows its procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased for the program. Response: The Department concurs with the finding and the need to strengthen controls to ensure the procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased are followed. Prior to the conclusion of the audit, the agency went live with its new procurement system, OpenGov in March 2025. OpenGov ensures that services are procured following policy and regulations. Corrective Action: The Department will ensure procurement rules and regulations are followed by enforcing the use of OpenGov throughout the agency. Name of contact person responsible for the corrective action: Dorthy Young Anticipated date for completion of corrective action: July 1, 2026

Cluster Name: Elementary and Secondary School Emergency Relief Assistance listing numbers and program names 84.425U COVID-19 – Education Stabilization Fund – American Rescue Plan Elementary and Secondary School Emergency Relief (ARP-ESSER) Agency: Arizona Department of Education (ADE) Name of contact person and title: Braulio Garcia, Chief Procurement Officer Anticipated completion date: June 2026 Agency’s Response: Concur 1. Follow federal regulation, State law, and the Arizona Procurement Code for procurements related to federal grant awards. ADE will conduct all procurements related to federal grant awards in compliance with 2 CFR Part 200, State law, and the Arizona Procurement Code, using the same policies and procedures applied to non-federal funds, as required by federal regulations. ADE will ensure appropriate procurement methods are used and documentation is maintained. Competition Impracticable (CI) procurements will require prior review and approval by the State Procurement Office (SPO) before implementation, and ADE procurement staff will consult with the SPO as needed for technical assistance to ensure ongoing compliance. Implementation is ongoing and monitored through procurement file reviews and established internal controls. 2. Update and implement policies and procedures and responsible employees to use competitive procurement methods or otherwise obtain approval from the State Procurement Officer and to prepare written determinations for exceptions to using competitive procurement methods, such as noncompetitive waivers, when purchasing goods and services from third-party vendors. ADE Procurement is currently updating internal policies and procedures, which shall be implemented by June 30, 2026, to ensure appropriate procurement employees consistently use competitive procurement methods or obtain prior approval from the State Procurement Office (SPO) when exceptions apply. The updated procedures will require written determinations and justifications, such as a Competition Impracticable (CI), for all exceptions to competition and will clearly define responsibilities and approval requirements when purchasing goods and services from third-party vendors. Procurement staff will follow the revised procedures for all applicable procurements, and compliance will be monitored through procurement file reviews and established internal controls.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The policy was revised at the end of the 2025 Fiscal Year. Additionally, a new and additional review process was put into place prior toentering a requisition for approval. This process requires all necessary documentation be furnished to the finance office prior to the requisition being approved. Completion Date: 7/16/2025

CORRECTIVE ACTION PLAN The Town of Billerica, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17th Floor Boston, MA 02109 Audit Period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding 2024-003: Missing Federally Required Procurement Clauses in Vendor Contracts Views of Responsible Officials: The Town is committed to strengthening its procurement practices and ensuring compliance with Uniform Guidance requirements. To address this issue, the Town will develop and implement standardized contract templates, and a comprehensive checklist of required federal clauses applicable to federally funded procurements for any future federal dollars. The Town will formalize procedures to ensure that a secondary review is consistently performed and documented for all required federal reports prior to submission and will designate a member of management or another qualified official to perform and document this review. Official Responsible for Implementing Corrective Action: Amit Chhayani Town Accountant

AEA agrees with the finding. Management acknowledges that, while the organization followed procurement guidance contained in the Weather Assistance Program Policies and Procedures Manual, it did not formally adopt an organization-wide written procurement and suspension and debarment policy fully compliant with 2 CFR Part 200.317–200.327. AEA will formally adopt a written procurement policy that incorporates all applicable Uniform Guidance requirements, including procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and procedures for suspension and debarment verification for covered transactions. Management will also implement related procedures and control documentation to support consistent application of the policy across federally funded programs. AEA will provide training to relevant personnel and will maintain documentation evidencing procurement review and suspension/debarment verification, where applicable. Management believes these corrective actions will bring the organization into compliance and reduce the risk of future noncompliance.

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury 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

Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award.Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization implemented internal controls over procurement and suspension and debarment compliance. Management will require documented verification of vendor eligibility through appropriate federal and state exclusion checks or signed certification, as applicable, before any procurement is finalized. All procurement-related documentation—including procurement method determinations, vendor selection support, debarment verification evidence, and required certifications—will be subject to supervisory review to ensure completeness and compliance with federal requirements. The Organization will retain all procurement and debarment documentation in the official procurement or contract file in accordance with federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2026.