Corrective Action Plans

2025-005 – Procurement Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations, procedures, and property and equipment management. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026

Federal Grantor: Department of Agriculture, Pass-Through: Nebraska Department of Education Program: Child Nutrition Cluster, Special Education Cluster Award No. and Year: 13898414/13897314/47600262900 and 2024, 24-6406-00-19-028-0001/24- 6408-00-19-028-0001/24-6411-00-19-028-0001/24-6412-00-19-028-0001/24-6418-132-28-0001P and 2024 Federal Assistance Listing Number: 10.553/10.555/10.559/10.582, 84.027/84.173 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Corrective Action: Management will work with the School Board to update the current procurement policy to include all requirements in 2 CRF 200. Name of Contact Person: Cindy Miserez, Controller (531) 299-9891 cynthia.miserez@ops.org Project Completion Date: June 30, 2026

Management's Response: The School District concurs with the recommendation. We recognize the importance of maintaining strong internal controls to ensure that all procurement activities are conducted in full compliance with Uniform Guidance (2 CFR Part 200) requirements. To address this recommendation, the District will enhance its existing procurement procedures by: 1. Developing and Formalizing Written Internal Controls. 2. Implementing Staff Training. 3. Strengthening Monitoring and Review Processes.

Community Project Funding/ Congressionally Directed Spending - Construction Community Project Funding – Assistance Listing No. 93.493 Recommendation: We recommend that the Organization formally documents its existing procurement and suspension/debarment practices in written policies that comply with 2 CFR Part 200. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The instance identified by the auditors was related to the Organization not having a written policy that documents its existing procurement and suspension/debarment practices. The Organization has outlined its response in the bullet points below: • The Organization implemented a formal, written policy that details their procurement and suspension/debarment practices and will follow this policy moving forward. Name(s) of the contact person(s) responsible for corrective action: Brian Holcomb, Controller Planned completion date for corrective action plan: Has been implemented If there are questions regarding this plan, please call Brian Holcomb, Controller, at 612-638-4900.

Audit Finding Reference: 2025-001 Planned Corrective Action: The Student Services and Food Service departments in Southwick-Tolland-Granville Regional School District will immediately ensure complete implementation of our internal control protocols regarding procurement. For any purchase that requires competitive procurement, we will conduct market research, obtain multiple quotes, or use the IFB/RFP process, if necessary. We will only engage in sole source procurement when we have determined that there is only one single provider of the good or service, and we will document that determination accordingly. We will enter into contracts with vendors when purchasing goods or services from them. We will use purchase orders to ensure that funds are encumbered and not over expended. Lastly, we will keep all procurement documentation on file, including quotes, bids, and sole source letters. Staff who engage in our purchasing process, including our Director of Student Services, our Director of School Nutrition, our Supervisor of Buildings and Grounds, and our Director of Technology will be retrained in our procurement protocols and will be expected to implement them immediately going forward. The Director of Finance and Operations will review all purchase requisitions to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 17, 2026 Person Responsible for Corrective Action: Nicholas Bernier Director of Finance and Operations Southwick-Tolland-Granville Regional School District

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Name of contact person: Michelle Richards – City Clerk/Treasurer Corrective Action: The city will develop a policy to provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and that no award, subaward, contract or agreement is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2027

Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: The District does not have a written procurement policy in place that satifies all provisions of Title 2 CFR Part 200.318 through 200.327. Responsible Individuals: Neil Breidenbach, System Manager Corrective Action Plan: The District will review the requirements of CFR sections 200.318 through 200.327 and update their procurement policy that meets the requirements. Anticipated Completion Date: December 31, 2026

Planned Corrective Action: Management will strengthen procurement policies, procedures, and documentation practices to ensure compliance with Uniform Guidance (2 CFR 200.318–200.327) and TxGMS general procurement standards. Actions will include: updating the procurement policy to clarify procurement methods and dollar thresholds; adopting a standardized procurement justification template for sole source determinations that requires documented rationale and supervisory approval; implementing a required procurement file checklist that documents the procurement method used, vendor selection process, quotes or bids obtained, and retained supporting documentation; instituting supervisory review and sign off of procurement classification and supporting documentation prior to award approval and payment; providing targeted training for Programs, Finance, and Procurement staff on procurement rules, sole source justification, and simplified acquisition documentation requirements; and performing a retrospective review of the two identified procurements to complete or document required supporting evidence and remediate any gaps. Finance will perform periodic testing of procurement files to verify adherence to the updated procedures and report findings to management and the Audit Committee. Responsible Parties: Kyle Bolls, Controller Ryan Parks, CFO Estimated Completion Date: September 30, 2026

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

US Department of Treasury Passed through Colorado Department of Human Services Federal Financial Assistance Listing 21.027 Award 24 IBEH 18932 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In our testing of procurement, suspension and debarment it was identified that the Organization did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326 implemented at the beginning of the fiscal year. In addition, there was no formal review of vendors to ensure they are not suspended or debarred prior to entering into transactions. Corrective Action Plan: Both of these two deficiencies will be dealt with through an updated procurement policy as well as a check list to ensure contracts comply with all federal guidelines. In addition, all processes needed to ensure compliance will be updated or created as needed. This recommendation has been implemented last fiscal year, however the deficiency remains as the corrective action wasn’t in place for the entire fiscal year. Responsible Individual(s): Karen DeGroot, Director of Finance Anticipated Completion Date: July 2025

Finding 2025-001 - Material Weakness Condition: Two (2) Next-Generation Facility Project (the Project) consulting contracts were procured in compliance with the Federal Transit Administration's (FTA's) procurement guidelines but did not conform with the Caltrans Local Assistance Procedures Manual (LAPM) Sections 10.01 and 10.1.9 of the LAPM, including not including a Public Interest Finding for the sole source procurement of the agreement, and the LeFlore group, LLC non-A&E consultant contract procurement did not comply with Section 10.3 of the LAPM. In addition, a Disadvantaged Business Enterprise goal was not requested nor completed as part of the advertisement for the project, which was required under Section 9.7.2 of the Caltrans LAPM. Recommendation: The Authority add additional language to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the Federal Highway Administration (FHWA). Management's Response: Management will ensure additional language is added to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the FHWA. The action will be completed with Board adoption of an updated Procurement Policies and Procedures Manual at or before its regular June 18, 2026, meeting. The contact person responsible for this action is Matthew Mauk, Executive Director, (530) 634-6880.

Corrective Action Plan Procurement Finding 2025-006 Roof Above will update the procurement policy to comply with Uniform Grant Guidance to include updated threshold criteria, publicizing bids, and checking for suspension and debarment of contractors. Roof Above will also update the corresponding procurement checklist to align with updated policy. Contact person responsible for corrective action: Kaedon Grinnell, Chief Program Officer Anticipated completion date: June 30, 2026

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of West Warwick’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The error will be corrected as of the beginning for fiscal year ending June 30, 2027. We will add the paragraph to our existing purchasing policy. This must be done by resolution and given the timeline that takes, we anticipate having this implemented the end of June 2026. Name of Contact Person Kristen Benoit, Finance Director Projected Completion Date 7/1/2026

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

NAMI Chicago acknowledges the finding and has revised the finance policy as of January 1, 2026 to clearly define micro-purchase thresholds and procedures for micropurchases, simplified acquisition thresholds and procedures for simplified acquisitions, formal procurement methods for use when transactions exceed acquisition threshold and noncompetitive procurement methods. Management will monitor procurement activity for compliance with the updated policy.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Water Conservation Grant Assistance Listing Number: 21.027 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 6, 2026 Planned Corrective Action: The District has designed and implemented policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. The Federal Programs Director and Procurement Clerk will check each vendor exceeding the formal procurement threshold for suspension or debarment.

Research and Development – Assistance Listing No. 20.000 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend that OSU STW and OSU CHS review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OSU STW: The cause of this issue was primarily due to time constraints associated with completing work, which led to procurement procedures not being followed and purchases being initiated prior to obtaining proper authorization. To address this issue, the organization requires completion of a Ratification of Unauthorized Commitment form for all instances where proper procurement procedures were not followed. These instances are tracked and monitored by the Procurement Office. In addition, personnel have been re-educated on procurement requirements, with specific emphasis that a PO must be in place and approved prior to the initiation of work or commitment of funds. OSU CHS will reinforce existing procurement policies and procedures for federally funded purchases. Management will provide targeted communication and training to departments to ensure that applicable procurement requirements (such as obtaining competitive quotes or sole source justification) are followed when purchases exceed established thresholds. This communication will emphasize that total expected cost, including shipping and handling when known, must be considered when determining the appropriate procurement method. Name(s) of the contact person(s) responsible for corrective action: OSU-STW Jorge Guerrero, Norb Delatte, Jean Kerr-Hunter. OSU-CHS Michael Sauer Planned completion date for corrective action plan: OSU-STW Completed April 30, 2024, OSU-CHS May 31, 2026

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.

Condition: The Organization lacked written procedures for federal cash management, allowability of costs pertaining to federal funds, procurement, conflicts of interest governing employees involved in federal contract administration, and verification that providers of covered transactions were not suspended, debarred, or otherwise excluded, as required under 2 CFR Sections 200.302, 200.318, and 180.300. Corrective Action Steps: Draft and adopt written federal cash management procedures consistent with 2 CFR Section 200.302(b)(6), including policies for minimizing the time between drawdown and disbursement of federal funds. Draft and adopt allowability of costs policy consistent with 2 CFR Section 200.302(b)(7), identifying the categories of costs allowable under federal awards and the approval process for charging costs to federal programs. Draft and adopt written procurement procedures consistent with 2 CFR Section 200.318(a), including competitive procurement thresholds, documentation requirements, and sole-source justification protocols. Draft and adopt a written standards of conduct / conflicts of interest policy consistent with 2 CFR Section 200.318(c)(1), applicable to all employees involved in the selection, award, and administration of federal contracts. Establish and document a process for verifying that all covered transaction providers are not suspended, debarred, or excluded prior to contract award, and retain evidence of each verification. Responsible Party: CLC NWI Executive Director. Target Date: May 15, 2026

We will reach out to MTAS to help the Town to write and implements a policy for the Federal Awards Program.

Audit Finding Reference: 2025-004 Improve Procurement Process for Child Nutrition Cluster Planned Corrective Action: The Portland Public Schools Child Nutrition Department will begin the process on March 16, 2026, to obtain a third vendor for small purchases. This action will ensure fair and equitable competition among vendors. The department will work with the Maine Department of Education Child Nutrition Program and Portland Public Schools to ensure full compliance with all procurement requirements. The Food Service Department will create procedures with vendors that supply goods to our program. Implementation of these contracts will begin as soon as a formal decision is made in coordination with the District's Purchasing Manager and the City of Portland. Planned Implementation Date of Corrective Action: 3/17/2025 Person Responsible for Corrective Action: Tyler Guerin, Food Service Director

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management compose a procurement policy with the criteria as set out in 2 CFR sections 200.318 and 200.326. and review the conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR section 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will compose a procurement policy in line with compliance requirements and review and edit the conflict of interest policy to be in compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

Jordan Kramer Chief Financial Officer 202-624-7787 January 2024 Management's Corrective Action Plan: NGA has previously developed and communicated our procurement processes and procedures to all staff members. We will provide additional training for employees involved in sourcing decisions during meetings, focusing on the accurate documentation of decision-making processes. In response to this finding, NGA will review the vendor selection processes for events over the past six months to ensure appropriate documentation is captured in the finance system. Ongoing training will be provided to new program staff regarding procurement documentation requirements to maintain compliance with established policies. When circumstances necessitate working with a specific entity or time constraints preclude a competitive process, program leaders and finance will collaborate to produce a memorandum detailing the work’s unique requirements and the criteria underlying vendor selection. Additionally, the CFO will coordinate with management to notify supervisors when procedures are not followed and to pursue corrective actions, ensuring all individuals complete the necessary compliance steps. The NGA Management Team deeply values the partnership with its Baker Tilly auditors as we address these concerns. Your expertise and guidance are crucial to our improvement process. Please ask any questions or provide feedback on management's action plans.

2025-002 Procurement Supporting Documentation Planned Corrective Action Plan: Heartwood will review federal grant requirements then will ensure that policies and procedures are in compliance with those requirements. Finally, documentation obtained during required procedures, will be centrally located to demonstrate compliance. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Sherri Sampson, Executive Director