Corrective Action Plans

2026-004 Procurement Corrective action planned: OMC will follow its current procurement policy and will seek bids for contracts with autorenewals, utilities, and professional services. However, OMC will also review its current procurement policy to see if changes are necessary to reflect the current environment to exclude items such as certain utilities and services from the bid process if such utilities and services are unique and limited to the service area of the health center and if only one option exists or the current vendor is performing sufficiently so that undue burden would be placed on the Organization to switch vendors, then a sole source justification will be documented, in both paper format and electronically so that records are readily available for review. Anticipated completion date: 08/31/2026 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

The District is in the process of reviewing its procurement practices. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

The District is in the process of reviewing its procurement practices. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

FA 2025-003 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $333,778 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The School District concurs with the finding and will strengthen internal controls to ensure that all expenditures charged to the Child Nutrition Cluster comply with applicable federal procurement and suspension and debarment requirements. • Review and update procurement procedures for federally funded Child Nutrition purchases to ensure compliance with federal, state, and District requirements. • Require documentation of suspension and debarment verification for applicable vendors prior to purchases using federal funds. • Implement a federal procurement checklist to document required quotes, approvals, procurement methods, and vendor eligibility verification. • Provide training to Finance, Purchasing, and Child Nutrition personnel on federal procurement and suspension/debarment requirements. • Conduct periodic reviews of Child Nutrition expenditures to verify that procurement and vendor verification requirements are being followed and properly documented. Estimated Completion Date: June 30, 2027 Contact Person: Kimberly Harrison Telephone: 912-427-1000 Email: kharrison@wayne.k12.ga.us

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 84.027A - Special Education Grants to States 84.173A – Special Education Preschool Grants H027A240073 (Year: 2025), H027A230073 (Year: 2024) H173A240081 (Year: 2025), H173A230081 (Year: 2024) $11,583 Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The School District will strengthen internal controls to ensure that all expenditures charged to the Special Education Cluster (as well as other federal program clusters) comply with applicable federal procurement and suspension and debarment requirements. • Review and update procurement procedures for federally funded purchases to ensure compliance with federal and District requirements. • Require documentation of suspension and debarment verification for applicable vendors prior to purchases using federal funds. • Implement a procurement checklist or verification spreadsheet and process for federal purchases to document required quotes, approvals, procurement methods, and suspension/debarment verification. • Provide training to Finance, Purchasing, and applicable school/district personnel on federal procurement and suspension/debarment requirements. • Conduct periodic reviews of federal expenditures to verify that procurement documentation and vendor eligibility checks are completed and maintained. Estimated Completion Date: June 30, 2027 Contact Person: Kimberly Harrison Telephone: 912-427-1000 Email: kharrison@wayne.k12.ga.us

Corrective Action Plan Finding 2025-002 Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Tim Stay, CEO Timeline: All future contract solicitations will follow the required procurement standards.

Finding Summary: NNCH did not properly procure three contracts in accordance with applicable procurement requirements and the Organization's procurement policy. Additionally, procedures were not sufficient to ensure that contracts contained all provisions required under Uniform Guidance. Responsible Individuals: Matthew Fleming, Executive Director; Jocelyn Kendall-Perez, Deputy Director & CFO Corrective Action Plan: Management acknowledges the finding and has reviewed the circumstances surrounding the contracts identified with the independent auditors. Two of the three contracts identified involved specialized professional services, including a development consultant whose engagement originated prior to NNCH's receipt of the applicable federal funding and a procurement management consultant. Although management considered the specialized nature and circumstances of these engagements when making the contracting decisions, NNCH recognizes that the procurement documentation maintained did not sufficiently demonstrate compliance with the applicable federal procurement requirements. As part of management's review of this finding with the independent auditors, NNCH discussed adopting a more conservative procurement approach for future contracting. Going forward, NNCH intends to evaluate and document procurements with the expectation that federal funding requirements may ultimately apply, even when federal funding is not anticipated at the time the contract is initiated. This approach is intended to provide greater flexibility if a funding source changes during the term of an engagement and to reduce the risk of an existing contract later being determined ineligible for federal reimbursement due to procurement requirements. NNCH will update its procurement procedures and develop a standardized procurement checklist addressing applicable procurement thresholds, required competition, documentation of permissible noncompetitive procurement when applicable, required approvals, suspension and debarment verification, and applicable federal contract provisions. Procurement documentation will be maintained with the applicable contract or project records. NNCH will also review applicable contracts prior to execution to verify that required procurement documentation and contract provisions have been addressed. Staff involved in contracting and procurement will receive guidance regarding the revised procedures and documentation requirements. Anticipated Completion Date: December 31, 2026

The Finance Officer, Cory Kappenman, is the contact person at this entity responsible for the corrective action plan for this finding. The City will establish controls to follow all applicable procurement requirements under the Uniform Guidance and applicable CFR sections.

2025-005 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance and Noncompliance – Procurement Recommendation: We recommend the Organization develop and implement a written procurement policy that complies with the Uniform Guidance procurement standards. The policy should require documentation of each procurement transaction, including the procurement method used, solicitation process, evaluation and selection criteria, contract award decision, basis for contract pricing, and retention of all supporting documentation. In addition, management should implement procedures to verify and document that contractors are not suspended or debarred prior to contract award and retain this documentation within the procurement file. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: JCWC is in the process of implementing updated procurement policies and procedures designed to strengthen compliance with Federal procurement requirements. The new Fiscal Policy Manual establishes procurement thresholds and a documented contractor procurement process. Section 6.2, Procurement Process, establishes procedures for developing solicitation packages, public advertisement, receipt of bids and proposals, evaluation, selection, and contract award. The policy also requires documentation of procurement activities and retention of supporting records. The revised policy specifically requires documentation of the reasonableness of contract pricing and verification through SAM.gov prior to contract award. Procurement records, including solicitation materials, proposals and bids, evaluation materials, selection or award justification, executed contracts, and SAM.gov eligibility verification, are retained in the procurement file. Action Plan: JCWC will finalize and present the Fiscal Policy Manual to the Board for formal adoption and will continue implementing the procurement procedures in the interim. Management will ensure that applicable procurements follow the required procurement method and that procurement files document the solicitation process, evaluation and selection, award decision, basis for contract pricing, SAM.gov eligibility verification, and other required supporting documentation. Following Board adoption, management will monitor compliance with the procurement procedures and address any gaps identified through ongoing review. Name(s) of the contact people responsible for correction action: Jennifer Hamilton, Executive Director Noah Jenkins, Conservation Director Plan completion date for corrective action plan: December 31, 2026 for implementation and monitoring ongoing.

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Housing Hope adopted a Procurement Policy that aligns with the Uniform Guidance following year end. The policy was communicated to all staff with purchasing and procurement responsibilities. The policy will be reviewed at least annually to ensure continued compliance with the Uniform Guidance. In addition, management conducts periodic reviews of procurement practices to verify compliance with the Policy. Anticipated completion date: The Procurement Policy was adopted November 2025 by the Board.

9. 2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that satisfy the requirements outlined in 2 CFR 200.318 through 200.327 and 2 CFR 180.220. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its current procurement policies, procedures, and internal controls as they relate to purchases made with federal funds. The University is assessing existing purchasing practices to identify areas where additional documentation, clarification, or controls may be needed to support compliance with applicable federal procurement requirements. As part of this work, management will review responsibilities and coordination among Sponsored Programs, Grant Accounting, the Business Office, Purchasing, and departments responsible for initiating and approving federally funded purchases. The University plans to strengthen and document processes surrounding appropriate approvals, purchasing methods, supporting documentation, vendor review, and other applicable federal requirements. Particular attention will be given to establishing clear ownership and appropriate checkpoints within the purchasing process so that compliance considerations are addressed before federally funded purchases are completed. The Office of Sponsored Programs, in collaboration with the Business Office and other affected departments, will support the review and development of updated procedures and provide guidance and training as processes are established. Management recognizes that strengthening the University's procurement framework will be an ongoing process and will prioritize improvements based on identified risk, operational needs, and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

Finding No.: 2025-013 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002, S403A240002 Area: Procurement and Suspension and Debarment Questioned Costs: $2,284,786 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding cost or price analysis and suspension and debarment requirements. GDOE recognizes that its procurement policies should clearly address the requirement to perform and document cost or price analyses for applicable procurements and contract modifications exceeding the simplified acquisition threshold. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement procedures should be reviewed periodically to ensure that applicable federal requirements are incorporated and that adequate controls are in place to demonstrate compliance. GDOE Supply Management Office will: 1. Review and update procurement policies to address the requirements of 2 CFR 200.324 for cost or price analysis. 2. Establish procedures and standardized documentation for cost or price analyses, including applicable contract modifications. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method, and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to ensure compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will be performed to verify that required cost or price analyses and suspension and debarment verifications are completed and documented.

Finding No.: 2025-007 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Federal Award No.: H027A230013, H027A240013 Area: Procurement and Suspension and Debarment Questioned Costs: $538,090 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding procurement and suspension and debarment requirements. GDOE recognizes the need to strengthen procurement procedures to ensure the appropriate procurement method is selected required documentation is maintained, and applicable contract modifications are properly supported. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement activities should be planned and reviewed sufficiently in advance to ensure that the appropriate procurement method is selected required approvals and documentation are completed, and services are not initiated before the procurement is properly executed. The GDOE Supply Management Office will: 1. Review and update procurement procedures to address applicable federal procurement requirements, including procurement methods, documentation, and contract modifications. 2. Establish procedures to evaluate similar or related services when determining the appropriate procurement method, regardless of funding source. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to monitor compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will verify compliance with procurement requirements and completion and documentation of suspension and debarment verifications.

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services in excess of $15,000, in which Auditor participated and was subsequently provided with the procurement operations and results, complete with Auditor’s own competitors. Vendor/Partner Contracts: The specific vendors and subcontractors were evaluated, vetted, and formally approved by the U.S. Department of Transportation (USDOT) during the competitive application and award phase of the Thriving Communities program. The Regulation: Under 2 CFR 200 (specifically regarding procurement by non-federal entities), if a federal awarding agency explicitly approves specific subrecipients or contractors as part of the federal award, it generally waives the requirement for subsequent competitive procurement for those designated roles. See USDOT-approved budget line items showing the named vendors (see USDOT Approved Budget” attached). All records are on file with the USDOT. Subrecipient/Contractor Monitoring: COMTO provided clear, signed agreements with these preapproved vendors that pass down all federal compliance requirements (e.g., Title VI, civil rights compliance, reporting metrics) required by the Thriving Communities program. Auditor has not clarified exactly which federal or local regulation they believe requires a rebid of USDOT-approved project partners (see executed contracts attached). COMTO does not run a competitive bidding or procurement process to select a subrecipient. They were selected as collaborative partners/sub-awardees and their status as subrecipients was explicitly authorized by the USDOT when they approved our grant award. All records are on file with the USDOT.

Finding 2025-06 Procurement and Suspension and Debarment: Inadequate Documentation of Competitive Bidding Procedures – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Planned Corrective Action Plan: APU will strengthen its procurement procedures to require retention of documentation supporting the procurement method used, solicitations, bids or proposals received, evaluation of responses, vendor selection, and the basis for the procurement decision when competitive procurement requirements apply. Procurement documentation will be retained in a centralized procurement file.; Anticipated Completion Date: July 1, 2027

Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: Testing of the federal program identified the following: a. The Organization’s formally documented procurement policy is missing one required element as it relates to domestic preferences (2 CFR 200.322). b. Two lease agreements were entered into where the Organization did not follow the procurement process as detailed in the procurement policy. The lease agreements with the vendors were also missing a required contract provision in accordance with Uniform Guidance and there was no review performed by the Organization to ensure the vendors were not suspended or debarred as the lease agreements with the vendors were over $25,000. Corrective Action Plan: Management will implement a checklist to ensure the Procurement Policy is being followed. In addition, management will review the procurement policy elements and update our procurement policy to ensure it incorporates all required elements. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director and Christina Thoelke, Business Manager Anticipated Completion Date: September 2026

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Stan Heil Contact Phone Number and Email Address: 812-542-0506-sheil@floydcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Floyd County has concurred with the material weakness finding and has accepted the recommendation provided of “we recommend that management of the County establish a proper system of internal controls and develop procedures to ensure that property and services are properly procured and that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards.” Floyd County will present all appropriate Requests for Proposal to the Commissioners for approval, publish in local arenas as required by statute, receive bids by defined deadlines, present to Commissioners for opening in a public setting, take under review with the County Attorney, and award according to statute timely. Dept of Treasury-Covid 19 funds, were paper files out for scanning and the County was unable to retrieve the specifics to support all needed functions requested during the Audit period. Documentation of past and future actions will be maintained in electronic retrievable format. All actions recommended and produced in this Corrective Action Plan have been, and will be adhered to for transparency, efficiency, and ethically. Anticipated Completion Date: The anticipated completion date of the Corrective Action Plan identified above will occur September 30, 2026 reporting as the exposure of this finding-weakness, is being addressed.

Procurement Policy – Assistance Listing Number 14.251 Recommendation: We recommend management update the procurement policy to be in line with Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to be in line with Uniform Guidance. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2027

2025-003 Under 2 CFR §200.318-326, non-federal entities must adhere to procurement standards for purchases made with federal funds. Key requirements include: - Full and Open Competition: Procurement transactions must be conducted to ensure open competition and prevent practices that may unduly restrict competition (2 CFR §200.319(a)). - Documentation of Procurement History: Entities must maintain records that detail the procurement history, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR §200.318(i)). - Use of Non-Competitive Procurement: Non-competitive procurement is only allowed under limited circumstances, such as when the item is available from a single source, there is a public emergency, or after solicitation of multiple sources, competition is deemed inadequate (2 CFR §200.320(c)). Recommendation: Implement comprehensive procurement policies and procedures that comply with federal regulations under 2 CFR §200.318-326. Ensure all procurement transactions are documented, including evidence of competitive bidding or justification for noncompetitive procurement under 2 CFR §200.320(c). Conduct staff training on procurement standards for federal awards, focusing on documentation, competition, and conflict of interest requirements. Perform periodic internal reviews to confirm compliance with procurement policies. Consult with California’s HCD regarding their expectations of contractor selection policies for the HomeKey program. Management Response: Management concurs with the recommendation and recognizes that procurement compliance requires both appropriate competition and sufficient contemporaneous documentation demonstrating how the procurement decision was made. HTM will strengthen its procurement framework to ensure applicable procurement requirements are identified before purchases are initiated and that the procurement file demonstrates the method used, competition obtained, selection rationale, required approvals, conflicts review, price or cost considerations where applicable, and justification for exceptions. Corrective Action Status and Plan: Management adopted a procurement policy July 2026 and plans to implement supporting procedures designed to comply with applicable federal, state, local, and award-specific requirements. By December 31, 2026, the Mission plans to issue detailed procedures and standardized procurement-file templates covering procurement method selection, applicable thresholds, independent cost or price analysis, full and open competition, solicitation and bid documentation, conflict-of-interest disclosures, contractor selection or rejection, contract type, price basis, required approvals, and permitted noncompetitive procurement justifications. Vendor onboarding will require documented suspension and debarment verification for each applicable vendor and contractor before commitment of funds, with evidence retained in the procurement file. Staff with purchasing, program, grant, and accounts-payable responsibilities will complete rolebased training, and completion records will be retained. Management plans to consult with California HCD regarding contractor-selection expectations for the HomeKey program and incorporate applicable requirements into the policy, procedures, and contract summaries. The Chief Financial Officer or designee will conduct and document periodic samplebased compliance reviews, track exceptions to resolution, and report material or recurring issues to executive management. Management plans to complete an operating-effectiveness review of procurement transactions and address identified deficiencies before year-end. Management also plans to implement a broader grant and contract compliance framework, as described in Finding 2025- 002, to establish responsibility for identifying, communicating, and monitoring compliance requirements associated with government funding agreements. Although a procurement policy was adopted in 2026, it was not fully operational during the audit period. Procedures to verify and document compliance with suspension and debarment requirements were also not consistently performed. As a result, compliance requirements associated with government-funded programs were not fully executed and documented during the year. These corrective actions will strengthen compliance with procurement regulations and suspension and debarment requirements, improve documentation and monitoring controls, and reduce the risk of future noncompliance with government funding requirements. Name of responsible persons: Emily Falappino, VP of Business Affairs, Ivet Samvelyan, VP of Mission and Impact and Tisha Lazare, Chief Financial Officer Anticipated completion date. December 31, 2026

Federal Agency Name: Corporation for National and Community Service Federal Financial Assistance Listing #94.012 Program Name: September 11th National Day of Service and Remembrance Grants Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: The organization’s procurement policy is missing required provisions in accordance with 2 CFR 200.318. For each of the 3 vendors selected for testing there was no documentation retained to support the rationale for the method of procurement. Additionally, the Organization did not retain supporting documentation to substantiate whether consideration was taken whether the vendor was suspended or debarred from doing business with the federal government prior to entering the covered transaction for each of the 3 vendors selected for testing. Corrective Action Plan: Management agrees with the finding and has revised its procurement policies and procedures to strengthen compliance with federal procurement requirements. The organization's Procurement Policy has been updated to incorporate applicable requirements of 2 CFR Part 200, including requirements governing procurement methods, noncompetitive procurements, conflicts of interest, contractor oversight, and suspension and debarment. Management has also implemented a standardized Sole Source Justification and Procurement Record for noncompetitive procurements. The record requires identification of the applicable basis for noncompetitive procurement under 2 CFR §200.320(c), documentation of the programmatic need and procurement rationale, consideration of available alternatives and applicable market research, documentation supporting cost or price reasonableness, suspension and debarment verification when applicable, and required internal approvals. Supporting documentation will be retained with the procurement record. For covered transactions subject to federal suspension and debarment requirements, management will verify the prospective contractor's exclusion status prior to entering into the transaction and retain dated evidence of the verification. Procurement documentation and required compliance reviews will be completed and retained prior to contract execution.

Finding 2025-006 United States Environmental Protection Agency Federal Financial Assistance Listing #66.458/66.468 Capitalization Grants for Clean Water State Revolving Funds Material Weakness in Internal Control over Compliance Finding Summary: In our testing of procurement, suspension, and debarment it was identified that the City’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Sarah Hellekson, City Administrator Corrective Action Plan: Management will establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2026

View of Responsible Officials: Management acknowledges the finding and agrees that documentation supporting compliance with procurement requirements was not consistently retained. For the seven disbursements selected for testing, management had established longstanding relationships with the vendors utilized and, in several instances, there were a limited number of vendors capable of providing the specialized equipment and services acquired for the project. Management indicated that procurement procedures were performed during the vendor selection process, including obtaining and evaluating quotes, discussing vendor alternatives, and visiting other healthcare organizations to assess the quality and suitability of certain products before making purchasing decisions. However, many of these activities occurred several years earlier, at the outset of the construction project, and supporting documentation was not maintained in accordance with the Organization's procurement policy and federal documentation requirements. Management agrees with the finding and will implement procedures to ensure procurement activities are conducted and documented in accordance with the Organization's procurement policy and Uniform Guidance requirements. Corrective actions will include establishing a centralized procurement file, providing additional training to personnel responsible for purchasing activities, and implementing supervisory review procedures to ensure that competitive procurement and documentation requirements are consistently met and appropriately retained.

Finding 2025-004 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2025 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: During the course of the engagement, it was identified that the Cooperative’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.327. In addition, the Cooperative did not follow procurement, suspension, and debarment procedures required under the Uniform Guidance prior to entering into contracts with vendors. Responsible Individuals: Kevin Mazure, Brad Essenmacher Corrective Action Plan: The Cooperative will update its written policy to include the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative will maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2026

Personnel Responsible for Corrective Action: Ryan Willhite, Executive Director, Internal Audit and ERM Anticipated Completion Date: 10/31/2026 Corrective Action Plan: Exclusion monitoring procedures were updated in June 2026 to memorialize expectations for documenting resolution of matches and submitting provider status change requests timely. Additionally, formal timing thresholds will be established for resolution of any UPH matches to exclusion listings.

Corrective Action: Management agrees with the finding. Management intends to develop and implement written policies and procedures, provide staff training, and establish a vendor verification process designed to ensure compliance with Uniform Guidance procurement and suspension and debarment requirements. Anticipated Completion Date: December 2026 Personnel Responsible for Corrective Action Plan: Cyndi Hanson, Chief Financial Officer