Corrective Action Plans

Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

Finding 2025-004 U.S. Department of Agriculture Federal Financial Assistance Listing/ALN #10.855 Distance Learning and Telemedicine Grants Federal Award #IA0714-BI17 2025 Procurement, Suspension and Debarment Material Noncompliance and Material Weakness in Internal Controlover Compliance Criteria: Uniform Guidance and 2 CFR §§ 200.318 through 200.326 establish the procurement standards that non-federal entities (other than states) must follow when expending federal awards. These standards require non-federal entities to maintain written procurement policies and procedures that ensure full and open competition, use of appropriate procurement methods based on dollar thresholds, and inclusion of required contract provisions as outlined in Appendix II to Part 200. Condition: The Hospital does not have a written procurement policy that conforms to the procurement standards under Uniform Guidance and 2 CFR §§ 200.318 through 200.326. In addition, testing of the Hospital’s only procurement transaction during the audit period disclosed the following instances of noncompliance: The procurement method used was not in accordance with Uniform Guidance requirements, as the contract amount exceeded the simplified acquisition threshold and a sealed bid or other allowable competitive procurement method was not obtained. The executed contract did not include all required contract provisions as prescribed by Appendix II to 2 CFR Part 200. Planned Corrective Action: Management is aware of the deficiency of internal control over the procurement, suspension and debarment direct and material requirement and subsequent to fiscal year end has implemented a formal procurement policy. Planned Completion Date: June 30, 2026 Person Responsible: Denise Hook, Chief Financial Officer

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our procurement for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to use our procurement process following our school board policies. NISEC has reported that for the 2023-2024 school year the corrective action plan was initiated by the below process. As a member of the Northwest Indiana Special Education Cooperative (NISEC), the School Corporation usually expends contracted services out of our general education fund. For the fiscal year of 2023-2024 we included our contracted speech services into our federal grant funds. During the audit the School Corporation was notified that we didn’t following the procurement procedures when expending out of the federal grant. This finding was due to the School Corporation not going out and receiving multiple bids for contracted companies that provide services to our students. The School Corporation uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding and discussing with the auditor we created a memo that we took to our board. In the memo we explain why we use the three contracted vendors instead of going out for bids. Finding Speech pathologist and Assistant are very difficult in the school setting and we have created great working relationships with these three contracted companies. Within the memo we list all of the contracted vendors we use and why we work directly with them instead of going out for bids. At the beginning of each school year we will take a new memo with any contracted companies that we will be using during the school year. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 31 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us Anticipated Completion Date: The Northwest Indiana Special Education Cooperative created the memo as soon as we received the finding and took the memo to the board. We have procedures in place now that any vendor that will exceed the simplified acquisition threshold, we will obtain bids or create a memo if bids are not an option. We took the memo to our October 9,2024 board. This was completed fully as of July 1, 2024. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate"

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: 5/31/2026. Responsible Contact Person: Anthony Daniels-Halisi, CEO.

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: January 31, 2026. Responsible Contact Person: Alfred D. Ivy, Director of Business Affairs & Operations.

The Organization concurs with the finding and is reviewing procurement policies to ensure adequate documentation is maintained.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement We will be updating the Policy 6325 for Micro purchases from $10,000.00 to $50,000.00. We are in policy review now. Suspension and Debarment All new vendors entered into the system are checked by the Corporation Treasurer through the Office of Inspector General search, printed and kept on file in the Corporation office. Further, all vendors used by the Food Service department have been updated to be current. Anticipated Completion Date: March 1, 2026

FINDING 2025-002 Finding Subject: Teacher and School Leader Incentive Grants – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

2025-001 Lack of Documentation for Procurement, Suspension, and Debarment Testing Federal Departments: Department of Health and Human Services, Administration for Children and Families Assistance Listing #: 93.496 Compliance and Internal Controls Significant Deficiency Category of Finding – Procurement, Suspension and Debarment Name of contact person: Vivian Huelgo, President and CEO Corrective Action: Finance staff will be responsible for maintaining and safekeeping all procurement documentation for requisite amount of time in accessible location in an accounting folder explicitly marked on the Esperanza United secured drive for finance staff and executive team. Completion Date: January 1, 2026

Federal regulations required full and open competition in procurement, equitable distribution of micro-purchases, cost/price analysis for formal contract, and proper contract management (2 CFR 200.318-326). Micro-purchases were not equitably distributed, cost/price analyses were not conducted prior to formal contracts, and full and open competition was restricted by unreasonable requirements. Sealed bids were not properly opened or evaluated, and contract management was insufficient. Purchsing staff attended a training during the Summer of 2025 that covered cumulative spend tracking, appropriate procurement methods, and required documentation for the various procurement methods. All documentation, including analyses, quotes, and vendor selection rationale, are uploaded within the purchasing module to ensure appropriate supporting documentation is kept with the purchase. Documentation is reviewd by the purchasing staff at the time each purchase order is requested.

The District will develop and implement procurement policies and procedure to ensure compliance with 2 CFR section 200.318 to 200.326.

Finding 2025-002 - Procurement (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management and leadership lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities had allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: None reported Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements early in the fiscal year and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: Yes Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. There has been a change in the General Manager position, to improve the operations, and training of all management, staffing and leadership. The Board has had significant membership change, with new leadership actively engaged in creating a quality internal control and policy environment. Much education and training has occurred during and after fiscal year 2024-2025, up through December 2025, and is ongoing, to meet these goals. Corrective Action Plan: The District acknowledges the weaknesses and its intention of correcting weaknesses. There has been a change in the General Manager position, to improve the operations, and training of all management, staffing and leadership. The Board has had significant membership change, with new leadership actively engaged in creating a quality internal control and policy environment. Much education and training has occurred during and after fiscal year 2024-2025, up through December 2025, and is ongoing, to meet these goals. Planned Implementation Date: December 31, 2025 Responsible Persons: District Board, Umpqua Public Transit District

HRSA Grant Self-Reporting Memo Deficiencies, Investigation, Reporting and Corrective Actions January 15, 2026 RE: Grant Number (FAIN): CE152520, under Assistance Listing Number: 93.493, Award Number: CE1HS52520-01-06 (the “Grant”) Federal Award Date: 9/21/2023 Grant Title: Community Project Funding/Congressionally Directed Spending - Construction Grantee: Spokane Guilds’ School (Unique Entity ID: DZJ5TZ4LGWH3, EIN: 91-0863163) (d/b/a Joya Child & Family Development “Joya”) 1016 N Superior St. Spokane, WA 99202 Grantee Contact: Colleen Fuchs, Executive Director Grant Purposes: Alteration and Renovation to Existing Facility, and related Equipment and other costs, to create Joya’s Neurodevelopmental Research & Training Institute Grant Amount (Per Notice of Award, Section 31. Approved Budget): e. Equipment $ 690,195.00 h. Construction/Alteration and Renovation $ 2,377,431.00 i. Other $ 117,114.00 Total Direct Costs $ 3,184,740.00 Less: Cost Sharing or Matching $ 184,740.00 Total Amount of Federal Share $ 3,000,000.00 Background: Joya’s facility was constructed from March 2021 to June 2022, and funded via private charitable contributions received from donors and a loan from Joya’s bank. The facility was placed in service in June, 2022 for a total approximate cost of $13.0 million. The facility is utilized by Joya, a 501(c)(3) non-profit organization, to house programs that provide physical, occupational, speech and other therapies to children with neurological and developmental delays, primarily from birth to three years of age. In Fall of 2022, Joya applied for a $3.0 million grant from HRSA to improve its facility to include a Neurodevelopmental Research & Training Institute and expand its services. The Grant was awarded to Joya, and Joya awarded a construction contract to the General Contractor who had completed its facility in 2022. The facility improvements were substantially completed in 2025. As of the date of this memo, approximately $123,000 remains available to Joya under the Grant. Procedural Deficiencies: 1. Competitive Bid (Eide Bailly Finding # 2025-001): In April 2025, during a selfreview of Joya’s compliance with 45 CFR Sections 75.326 to 75.335, specifically the required procurement procedures, management discovered that Joya’s procurement procedures were deficient in the following specific area. Joya’s policies and procedures did not require public notice to be issued regarding a competitive bidding process for the facility improvements, specifically the construction contract award, as required in the CFR. The contract was awarded to the same contractor who had recently constructed the original facility, as the contractor possessed critical knowledge of the facility along with the requisite skills to perform the improvements. However, market cost information (obtained through a public bid process) was not available. Further, a sample of nine transactions (out of 43 total transactions) indicated that contracts for three vendors between $10,000 and $250,000 required Joya to follow simplified acquisition procedures and obtain rate quotations in advance of procurement. 2. Proportion of Federal to Non-Federal Share (Eide Bailly Finding # 2025-002): Later in 2025, Joya engaged its independent CPA firm, Eide Bailly to audit its financial statements, and as part of that, to issue an opinion on its internal controls over financial reporting and on compliance with certain provisions of laws, regulations, contracts and grant agreements. During its review, the CPA firm discovered that Joya’s procedures regarding matching/cost sharing were deficient. Joya’s policies and procedures did not have su􀆯icient internal controls to ensure that grant funds were drawn down following the required proportion of (i) the Federal Share of Grant funds in proportion to (ii) the Cost Sharing/Matching Grant funds. Following a review of Joya’s financial records, it was determined that Joya’s contribution of its Non-Federal Share of improvement costs was approximately $12,000 lower than the amount required by the defined contract proportion, through June 30, 2025. Self-Investigation and Reporting: Joya’s investigation and specifically its review of the Grant requirements and the CFR language in April 2025, along with its seeking an independent review of its internal controls resulted in identifying both procedural deficiencies described above. Corrective Actions: The following corrective actions to address the Procedural Deficiencies have all been completed, as further described below. 1. Joya’s Director of Business and Accounting (B. Judge) timely notified its independent CPA firm, Eide Bailly, which described the internal control deficiencies in its qualified opinion to its Independent Auditor’s Report on Internal Control and Compliance for the year ended June 30, 2025. The CPA firm did not qualify its separate opinion to Joya’s Audited Financial Statements for the year ended June 30, 2025. 2. In April 2025, Joya’s Director of Business and Accounting (B. Judge) sought technical guidance and approval from Joya’s board of directors and its independent CPA firm. By June 2025, Mr. Judge had updated Joya’s policies and procedures to include the required internal controls described above. 3. Joya’s Director of Business and Accounting (B. Judge) engaged MACC Estimating Group, an independent construction estimation firm in Liberty Lake, WA, to obtain an itemized cost estimate for the facility improvements funded by the grant. The independent results issued on June 24, 2025 were only 6% higher than the awarded contractor bid. Joya’s management believes this provides a reasonable market cost for its awarded project. 4. On April 18, 2025, Joya’s Director of Business and Accounting (B. Judge) emailed HRSA sta􀆯 members A. Glasser and C. Barnes, o􀆯icially notifying HRSA of its procurement policy deficiencies. HRSA (A. Glasser, Grants Management Specialist) responded via email on April 18, 2025, asking about the procurement process Joya ultimately used, and informing Joya as follows: “At this time, all HRSA conditions for award CE1HS52520 have been met, and you are free to draw down funds from document number 23CE1HS52520 in the Payment Management System. However, please ensure that the terms outlined on the Notice of Award dated 9/21/23 are followed. If you have specific questions regarding these terms, I am happy to discuss further.” Joya has received no further correspondence from HRSA on the matter. 5. Joya’s Director of Business and Accounting (B. Judge) continued to monitor its procurement process and proportional cost sharing to remain in compliance with 45 CFR Sections 75.326 to 75.335. Specifically, Joya’s Accounting Policies were updated in 2025 to include the following internal controls, as reviewed and amended from time to time: “If a purchase is funded in whole or in part by a Federal Grant, any related procurement or payment must comply with Federal Grant Procurement policies and applicable Federal Regulations under 2 CFR §§ 200.317– 200.327, including, but not limited to: • Following allowable procurement methods (micro-purchase, small purchase, sealed bids, competitive proposals, or noncompetitive proposals) • Obtaining multiple quotes when required and providing public notice requesting sealed competitive bids for expenditures over $250,000 • Avoiding conflicts of interest • Ensuring that contractors have not been suspended or debarred • Documenting the basis for selection and price reasonableness • Ensuring that Joya monitors expenditures to ensure that it maintains the appropriate proportion of Federal Share of Grant funds in proportion to the Cost Sharing/Matching Grant funds”. 6. In February 2025, Joya received a private grant in the amount of $178,000 from a private donor, which served as 96% of the required shared/matching funds Joya required for the entire Grant. These and other Joya funds are su􀆯icient to meet 100% of the required shared/matching funds.

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procurement standards of 2 CFR sections 200.318 through 200.326, and procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200. Specifically, 2 CFR sections 200.430, 200.431, and 200.475 require written policies concerning compensation for personal services, fringe benefits, and travel costs, respectively. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures after yearend that were the policies and procedures followed during the year under audit and meets the requirements of Subparts D and E of 2 CFR Part 200. Contact Person: John Jacques Date of Completion: November 14, 2025

Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures for procurement. Management confirmed policies and procedures were followed and monitored during the construction of the project. Written policies and procedures were completed after year-end. Contact Person: John Jacques Date of Completion: November 14, 2025

Department of Education The Town of Ridgefield respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. COMPLIANCE FINDING SIGNIFICANT DEFICIENCY Procurement and Suspension and Debarment Recommendation: The Town should review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Town will review its policies to ensure it aligns with 2 CFR sections 200.318 and 200.326. They will communicate with the appropriate personnel any changes to their policies to ensure compliance in the future. Name of the contact person responsible for corrective action: Jill Browne, Director of Finance Planned completion date for corrective action plan: June 2026

Special Education Cluster (IDEA) – Assistance Listing No. 84.027/84.173/ Recommendation: We recommend the district add internal controls over monitoring vendor purchases throughout the fiscal year and comparing them to procurement policies to ensure proper procedures are followed in accordance with 2 CFR 200.319. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will continue to review its internal controls and modify policies and procedures, as necessary. Additional training will be attended by staff to rectify this matters for future years. Name(s) of the contact person(s) responsible for corrective action: Julie A. Stone, Director of Business Services Planned completion date for corrective action plan: The District plans to have the finding corrected by the reporting period ending June 30, 2026.

Auditor Description of Condition and Effect. During our review of procurement transactions, we identified one instance of sole-source procurement for which the College did not properly document a procurement decision in accordance with 2 CFR 200.320 related to justifying the use of a noncompetitive procurement method. Specifically, the procurement files lacked written justification demonstrating why competition was not feasible and did not include evidence of required approvals in accordance with the College’s procurement policies even though the arrangement was allowable under the circumstances. As a result of this condition, the College could not document a procurement decision for one vendor in accordance with federal regulations. Auditor Recommendation. We recommend the College strengthen controls over sole-source procurements by requiring documented justification and formal approval prior to executing noncompetitive procurement arrangements. Management should also provide additional training to procurement and program staff to ensure consistent compliance with federal procurement requirements and internal policies. Corrective Action. The entity will strengthen procurement controls by requiring written justification and documented approval for all sole-source procurements in accordance with Uniform Guidance and the entity’s procurement policies. A standardized sole-source justification form will be implemented and required prior to execution of any noncompetitive procurement funded with federal awards. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. June 30, 2026

We agree that our current procurement policies are not compliant with current federal regulations. We have reviewed the required policies and will adopt these policies in fiscal year 2026. Management will review their current procurement policies and make any necessary changes to update the policies to be compliant with 2 CFR Sections 200.138 – 200.327. We anticipate that the corrective action will be completed within 12 months.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 7AZ300AZ3, 6AZ300400, 7AZ310AZ1 Contact Person: Dominick Ruth, Director of Finance Anticipated Completion Date: July 1, 2025 Planned Corrective Action: Creighton School District #14 will review vendor awards in Visions and ensure that expired awards or awards that do not qualify as a competitive procurement awards are removed from the ERP system. In FY26, and in future the fiscal years, the District will obtain three written quotes for the Nutrition department's purchases from the associated vendor.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Contact Person: Shannon Kavanagh, Executive Director of Business Services Anticipated Completion Date: October 14, 2025 Planned Corrective Action: Upon finding that the District was not compliant with Federal, State, and Board policies and regulations governing procurement, a Request for Procurement was issued for the services received by the awarded vendors. The RFP was issued October 14, 2025. Moving forward, the District is taking additional steps to review the procurement requirements for the purchase of like items over $100,000 with the Executive Director of Business Services, the Assistant Director of Business Services, and the Purchasing Accountant/Buyer. The District will also be reviewing this requirement District‐wide with individuals responsible for purchasing during one of the ten purchasing workgroup meetings annually.

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

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

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION AND GRANT NUMBER AC-22-0096, GRANT PERIOD - YEAR ENDED JUNE 30, 2025 Name of contact person: Mayor and City Council Corrective Action: The city has scheduled a meeting with engineers to discuss this issue and to make sure that, before the next federal funded project is started, all parties understand the procurement and suspension and debarment requirements. We intend to ensure that the procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchases of goods or services is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2026

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