Corrective Action Plans

Corrective Action Plan Contact Person(s): Janet Carbary, Deana Gilpin Management agrees with this finding and recognizes the need to strengthen internal controls over purchasing processes to ensure compliance with Uniform Guidance requirements (§200.317–§200.326; §200.213). To address the deficiency, the Organization will implement the following actions: 1. Update Purchasing Policies and Procedures o Purchasing policies will be revised to clearly incorporate Uniform Guidance requirements, including competitive bidding thresholds, procurement method selection, and documentation standards. o Policies will explicitly require verification of suspension and debarment status for all vendors receiving federal funds. 2. Implement Mandatory Suspension and Debarment Verification o Staff will be required to document verification through SAM.gov or other approved sources before awarding or renewing contracts funded by federal awards. o A verification will be maintained and reviewed by Finance leadership. 3. Enhance Procurement Documentation Controls o Leadership will ensure all federal purchases meet the requirement below before purchase approval. • Competitive purchasing requirements are met • Cost/price analyses are documented when required • Suspension/debarment verifications are completed and retained 4. Training for Finance Staff o Staff involved in purchasing, contract approval, and grant management will receive training on Uniform Guidance procurement rules and suspension/debarment requirements. 5. Periodic Internal Monitoring o Revenue accountant will monitor expenses related to federal programs monthly to ensure compliance. o Senior management will be notified if corrective steps are needed. Anticipated Completion Date: December 31, 2025 Responsible Officials: • Chief Financial Officer (CFO) • Accounting Manager • Director of Financial Planning

Suspension and Debarment Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management recognizes that even though none of the vendors utilized were suspended, debarred or otherwise excluded, the potential for violations increase if the verification is not done prior to engaging in transactions. For grant expenses with federal funding, LCHC management has implemented mandatory SAM.gov verification for all vendors prior to contract execution, with documentation retained in procurement files. LCHC has held meetings where applicable staff have been informed of compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025 If there are any questions regarding this plan, please call Jeffrey Nelson at 872-588-3033

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

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. Kayla Quick, Accounts Payable Clerk. 6/30/2026

Criteria: According to 2CFR 200.318(i) the recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The School did not maintain records for food and construction vendors that met the acquisition thresholds for the year. Cause: The School's procurement policies do not address the frequency of which vendors should be evaluated. In addition, the policies also do not address records retention. Potential Effect: The procurement may not have been proper under the grant requirements.Recommendation: We recommend that the School follow federal procurement guidelines for each of the different purchase thresholds for each vendor. We further recommend that the School retain any documentation created related to the procurement selection and vetting process. Action: As of the date of this exit conference, we will adopt the above recommendations, securing and retaining the appropriate documentation of vendor selection and retention.

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

OBI will update current purchasing and procurement policy to specifically address the acquisition of property or services using federal grant funds to ensure adherence to Federal procurement standards in 2 CFR Part 200 sections 200.317-200.327. Our policy will outline requirements regarding vendor selection and vendor qualification. It will address the simplified acquisition threshold, micro purchases threshold, and the formal procurement methods that must be adhered to when the value exceeds those thresholds. The policy will include when sealed bids, proposals/requests for proposals are required and when sole source procurement is appropriate and allowable. Whenever sole source procurement is used, the rationale will be documented and approved. Our policy will include language requiring that all vendors and contractors paid using federal funds be checked for federal suspension & debarment using Sam.gov. Vendors found on the exclusion list will not be paid using federal funds. The policy outlines requirements for written approvals and documentation of all procurements. Additionally, OBI has implemented procedures to ensure that at the point of receiving the Notice of Award, any federal money or grant awarded to OBI will be immediately communicated to the CFO, Controller, and the Senior Accountant. Person(s) Responsible: Senior Accountant with review and approvals from Controller and CFO Estimated Completion Date: January 31, 2026

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

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026

2025-003 – Lack of Written Findings and Questioned Costs. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Ross Wilson, Village Clerk/Treasurer. Anticipated Completion Date: February 2026.

Health Center Program Cluster – Assistance Listing No. 93.224/93.527 Recommendation: The auditor recommends management implement suspension and debarment verification process for all covered vendors, regardless of their history or reputation, to ensure compliance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the recommendation: Management agrees with the finding and acknowledges that timely suspension and debarment verification was not consistently performed across all vendors. To address this deficiency, the Agency is implementing a standardized process to ensure suspension and debarment checks are conducted prior to entering into any covered transaction, regardless of vendor history. This process will include documented verification steps, annual review protocols, and staff training to reinforce compliance with federal procurement regulations. Name(s) of the contact person(s) responsible for corrective action: Chuck Walzel, CPA, Senior Vice President & Chief Financial Officer, 210-334-3724 (office) Planned completion date for corrective action plan: August 31, 2025

FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Corrective Action Plan: We will create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200. Proposed Completion Date: March 31, 2026

Finding 2025-003 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Procurement Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The entity has not established or documented a formal procurement policy or procedures to guide the acquisition of goods and services. No written guidelines were provided during the review period. Management Response: Management intends to establish a procurement policy. Status: In progress Anticipated Completion Date: Estimated 2025

The Capital District YMCA will develop and implement a written procurement policy in accordance with 2 CFR Section 200.318 and have it in place by July 31, 2025. The SVP/CFO Mary Maziejka will be responsible for development and implementation of the policy.

Condition: ALC has not implemented all policies and procedures required by 2 CFR Part 200, specifically for cash management, allowability of costs, procurement, compensation, and fringe benefits. Planned Corrective Action: The American Loggers Council will develop written policies and procedures to comply with 2 CFR Part 200, specifically for cash management, allowability of costs and procurement. Policies and procedures related to compensation and fringe benefits currently do not apply to the Organization because they do not have any employees. These policies and procedures will be reviewed and approved by the executive director and executive committee. Contact Person: Scott Dane Anticipated Date of Completion: December 2025

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Woodland January 1, 2024, through December 31, 2024 This schedule presents the corrective action the district plans to take for the findings included in this report, in accordance with Title 2 of the U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The Port did not have adequate internal controls and did not comply with federal procurement and suspension and debarment requirements. Name, address, and telephone of District contact person: Debbie Karlsson, Interim Deputy Director/Finance Administrator 1608 Guild Road Woodland, WA 98674 (360) 225-6555 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement.) The Port will implement new procedures that conform to the Port’s existing policy to verify suspension-and-debarment status of all applicable contractors in the future. This includes performing verification, modifying future contract language, and retaining evidence of verification. The Port is currently restructuring staffing and work functions, which will provide more clarity to staff on their specific roles and responsibilities. This will also allow the Port to make sure staff have sufficient training to carry out those responsibilities in accordance with the updated internal controls, including compliance with the Build America, Buy America Act. Anticipated date to complete the corrective action: March 31, 2026

Corrective Action Plan – Finding 2024-002 – Reporting Town of Van Buren – CFDA 21.027 – Coronavirus State and Local Fiscal Recovery Funds Audit Period: Fiscal Year Ended June 30, 2024 Views of Responsible Officials: The Town of Van Buren acknowledges the auditor’s finding regarding the lack of documentation for quarterly performance reports required under 2 CFR 200.329. However, it is important to clarify that, during the grant period, the Town communicated with Efficiency Maine Trust regarding these expectations. Efficiency Maine Trust, as the pass-through entity, confirmed that such federal performance reporting was not required to be submitted back to them by the Town as part of their grant process. Additionally, upon review of the contract provided to the Town, it was noted that the Town was inaccurately listed as a "co-recipient" of the SLFRF (State and Local Fiscal Recovery Funds). After multiple discussions with representatives from the U.S. Department of the Treasury – SLFRF team, it was confirmed that this designation was erroneous. The Town of Van Buren was not a co-recipient but rather a beneficiary of the ARPA funds administered by Efficiency Maine Trust. As a beneficiary, the Town was not responsible for direct federal reporting to Treasury, and this misclassification contributed to the confusion regarding reporting responsibilities. Corrective Action Plan: To prevent similar issues in the future and ensure full compliance with all federal award terms and conditions, the Town will implement the following measures: 1. Clarification of Role: All future grant agreements will be reviewed to confirm whether the Town is operating as a recipient, subrecipient, or beneficiary, and appropriate obligations will be documented. 2. Federal Reporting Procedures: For grants that include federal reporting obligations, the Town will establish an internal checklist outlining the specific reporting requirements and due dates upon award acceptance. 3. Training and Compliance: Staff responsible for grant administration will receive annual training on 2 CFR Part 200 requirements, including those relating to reporting and roles under federal awards. 4. Documentation and Recordkeeping: All communications with pass-through entities and federal agencies relating to grant requirements will be documented and retained as part of the grant file. By implementing these internal control enhancements, the Town aims to prevent future findings and ensure clarity in grant compliance responsibilities.

Corrective Action Plan – Finding 2024-002 – Reporting Town of Van Buren – CFDA 21.027 – Coronavirus State and Local Fiscal Recovery Funds Audit Period: Fiscal Year Ended June 30, 2024 Views of Responsible Officials: The Town of Van Buren acknowledges the auditor’s finding regarding the lack of documentation for quarterly performance reports required under 2 CFR 200.329. However, it is important to clarify that, during the grant period, the Town communicated with Efficiency Maine Trust regarding these expectations. Efficiency Maine Trust, as the pass-through entity, confirmed that such federal performance reporting was not required to be submitted back to them by the Town as part of their grant process. Additionally, upon review of the contract provided to the Town, it was noted that the Town was inaccurately listed as a "co-recipient" of the SLFRF (State and Local Fiscal Recovery Funds). After multiple discussions with representatives from the U.S. Department of the Treasury – SLFRF team, it was confirmed that this designation was erroneous. The Town of Van Buren was not a co-recipient but rather a beneficiary of the ARPA funds administered by Efficiency Maine Trust. As a beneficiary, the Town was not responsible for direct federal reporting to Treasury, and this misclassification contributed to the confusion regarding reporting responsibilities. Corrective Action Plan: To prevent similar issues in the future and ensure full compliance with all federal award terms and conditions, the Town will implement the following measures: 1. Clarification of Role: All future grant agreements will be reviewed to confirm whether the Town is operating as a recipient, subrecipient, or beneficiary, and appropriate obligations will be documented. 2. Federal Reporting Procedures: For grants that include federal reporting obligations, the Town will establish an internal checklist outlining the specific reporting requirements and due dates upon award acceptance. 3. Training and Compliance: Staff responsible for grant administration will receive annual training on 2 CFR Part 200 requirements, including those relating to reporting and roles under federal awards. 4. Documentation and Recordkeeping: All communications with pass-through entities and federal agencies relating to grant requirements will be documented and retained as part of the grant file. By implementing these internal control enhancements, the Town aims to prevent future findings and ensure clarity in grant compliance responsibilities.

Finding #SA2024-004 Compliance with Procurement Requirements Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: A-00216-01 • Name(s) of the contact person: Melissa Munoz, Interim Assistant Finance Director • Corrective Action Plan: Staff recognize that importance of following the current purchasing policy and retaining the proper records. Finance staff are working with the departments to ensure the documentation is being attached to all purchases and retained electronically. Critical positions that were vacant within the department have been filled, which has helped alleviate some of these issues. The City is in the development phase of the purchasing policy and is actively working with a consultant on the policy. This policy will be partially implemented in Fiscal Year 2026. • Anticipated Completion Date: 6/30/2026

In our audit findings there was noted $555,000 in bids awarded were not properly advertised. There was an advertisement for a pre-bid meeting for the projects. The projects were the removal of blockages on Rough River with money received from NRCS for that purpose. The intention was for the ad to say the projects were open and that bids were to be received by a certain date. The ad was improperly ran but not intentionally. We will double check all items going to bid. If an item is sent by any department it will be double checked at the Judge Executive's office. If it originates here it will be double checked by the treasurer's office.

Finding ref number: 2024-001 Finding captions: The district did not have adequate internal controls ensuring accurate reporting of its financial statements. Name, address, and telephone of District contact person: Erick Brittain, Fire Chief PO Box 1449, Soap Lake, WA 98851 (509) 246-0321 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). 1. Develop and implement Written Policies and Procedures- The District will immediately develop formal, written internal control policies and procedures specific to financial reporting. This will include a robust internal review process to ensure all financial statements are accurate, properly supported and classified correctly prior to submission. Assigned to: Fire Chief and Administrative Assistant 2. Mandatory Financial Reporting Training: The Administrative Assistant and Fire Chief will attend ongoing training on Budgeting, Accounting and Reporting System (BARS) to gain a comprehensive understanding of proper financial reporting requirements and principals Assigned to: Fire Chief and Administrative Assistant 3. Cross Training and Segregation of Duties: The District will establish clear segregation of duties to ensure no single employee has control over all steps of a financial transaction or reporting process. The Administrative Assistant and Fire Chief will be cross trained to provide independent secondary review of the financial statements as well as obtaining Board of Commissioner Approval. Assigned to: Fire Chief and Administrative Assistant. 4. Contract with a third-party scheduling platform: The District will contract with a third-party vendor to accurately track employee time off in accordance with Grant County Fire District #7 paid time off policy. Assigned to: Fire Chief. Anticipated date to complete the corrective action: Ongoing/ December 31st 2025 Finding ref number: 2024-002 Finding captions: The district did not have adequate controls and did not comply with federal suspension, debarment and procurement requirements Name, address, and telephone of District contact person: Erick Brittain, Fire Chief PO Box 1449, Soap Lake, WA 98851 (509) 246-0321 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). 1. Develop and Implement Comprehensive Procurement and Public Works Policies: The District will immediately develop and adopt robust written procurement and public works policies and procedures. These policies will ensure compliance with both federal regulations and Washington state law (RCW). The policies will include detailed procedures for: ○ Vendor and Subcontractor Vetting: Incorporating explicit steps for checking potential vendors against the federal System for Award Management (SAM) database to ensure they are not suspended or debarred. This process will apply to all federally funded procurements, as well as any other procurements exceeding the federal threshold of $25,000 paid with federal funds. ○ Competitive Bidding: Establishing clear thresholds for purchases and public works projects requiring minimal, informal, or formal competitive bidding, in line with state guidelines. ○ Public Works Requirements: Mandating compliance with prevailing wage requirements and incorporating bonding and retainage rules for all public works projects. ○ Documentation: Requiring detailed record-keeping for all procurement activities, including bids, vendor evaluations, and justification for contract awards. ○ Contract Clauses: Including a standard contract clause affirming vendor understanding and compliance with federal debarment and suspension requirements. ○ Policy Approval: Submitting the draft policies for review and adoption by the district’s governing body. ○ Assigned to: Fire Chief and Administrative Assistant. 2. Conduct Staff Training: All relevant staff, particularly the Fire Chief and Administrative Assistant, will undergo mandatory training on the new policies and procedures. Training will cover the correct application of procurement rules, the importance of federal suspension and debarment checks, and proper documentation procedures. ○ Assigned to: Fire Chief. 3. Implement Management Review and Oversight: The Fire Chief will conduct and document a review of all procurement and public works transactions to ensure compliance with the newly adopted policies before any contract is finalized, or a purchase order is issued. ○ Assigned to: Fire Chief. 4. Establish Periodic Compliance Self-Assessment: The District will perform annual self-assessments of its procurement process to identify and correct any control weaknesses and ensure ongoing compliance with federal and state regulations. ○ Assigned to: Fire Chief Anticipated date to complete the corrective action: Ongoing/ December 31st, 2025.