Corrective Action Plans

The District’s Business Manager will obtain quotes/bids when necessary.

FA 2024-001 Improve Controls over Procurement Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: 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 COVID-19 - 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 245GA324N1199 (Year: 2024) 245GA324L1603 (Year: 2024) 245GA324l1603 (Year: 2024) $5,380.74 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 procedures were followed. Corrective Action Plans: Implement a standardized procurement checklist that must be completed. Procurements will require two levels of review (program level review by child nutrition staff and District level) to confirm compliance before processing payments. District will provide staff training to ensure federal procurement regulations, district procurement policies along with documentation and recordkeeping requirements are being met. The finance department will conduct quarterly internal reviews of Child Nutrition expenditures to verify compliance. Estimated Completion Date: November 10, 2025 Contact Person: Jon Erik Jones, Superintendent Telephone: 229.321-1487 Email:jones@quitman.ki2.ga.us

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.

Contact Person(s): Sarat Puthenpura Corrective action planned: ONF is in the process of upgrading its current written procurement policy to better comply with Federal audit requirements. The policy will be updated to include: • Inclusion of services under coverage of the policy • Micro purchase threshold explicitly defined. • Clear provisions for maintaining detailed procurement records including a requirement that such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. • The simplified acquisition threshold explicitly defined and incorporates all relevant elements including sealed bids method. Anticipated completion date: 11/30/25

CHA currently has a general procurement plan in place to guide its purchasing and contracting activities. However, to ensure full compliance with federal regulations, CHA will be updating its existing procurement policy to align with the Uniform Guidance requirements. This update will formalize procedures related to vendor selection, competitive bidding, and documentation to maintain transparency, accountability, and consistency across all procurement processes.

U.S. Department of Health and Human Services Material Weakness in Internal Controls over Compliance and Material Noncompliance: Procurement, Suspension and Debarment Recommendation: CLA recommends the Alliance to develop the procurement policy compliance in with Uniform Guidance, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Alliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HIV Alliance updated our Procurement Policy to comply with the federal guidance using the recommendation provided by CLA. The Board of Directors voted toapprove the updated Procurement Policy in June of 2025 and we implemented the updated policy on July 1, 2025. Name(s) of the contact person(s) responsible for corrective action: Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION, GRANT No. AM-23-0295, YEAR ENDED JUNE 30, 2024 Name of contact person: Mayor and City Council Corrective Action: The city procurement policy will be updated to include references to all federal procurement standards and requirements. All directors and relevant individuals will be trained on the updated policies. Proposed Completion Date: December 31, 2025

Management accepts the recommendation and will ensure compliance with the procurement standards in 2 CFR §§ 200.318–200.327 for all federally funded purchases by either conducting a competitive bidding process or documenting and obtaining approval for a sole source procurement as allowed under 2CFR §200.320(c)

Formula Grants for Rural Area and Tribal Transit Program Federal Assistance Listing #20.509 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 and state requirements for procurement. The Organization should ensure documents are retained to support whether procurement policies were followed for vendors procured in years past. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review the procurement standards as well as ensure documents are retained to support whether procurement policies were followed. Name(s) of the contact person(s) responsible for corrective action: Carrie Beithon, Director of Financial Services Planned completion date for corrective action plan: 12/31/2026

Internal Controls over Compliance and Compliance with Procurement Standards Individual Responsible for Corrective Action Plan: Christopher Holleman, Interim CFO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Management will ensure that the policy be redistributed for retraining purposes underscoring the vital importance of following the policy and federal guidelines related to procurements. In addition, the CFO will take lead to ensure that the procurement policy is appropriately applied, and documentation meets required standards.

The Village will ensure that proposals be submitted for architectural and engineering professional services, and that documentation will be maintained for the proposals obtained as well as the Village’s determination of the most qualified vendor.

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Below $50k there will also be formal procedures with increasingly more oversight for purchases as they increase in cost. We will form and document a detailed procedure for issuing RFPs for PO amounts over $50k. We will review at least 3 proposals and once one is chosen, the vendor will be vetted before the proposal is accepted.

FINDING 2024-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: K. Rochelle Seneff Contact Phone Number and Email Address: (812)649-2242 ct@rockportin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement As Clerk-Treasurer, I will educate all parties involved on the requirements that were found to be unfulfilled through this Federal Audit. For the duration of any federally funded projects, a discussion will be held during a public board meeting, detailing the rationale behind the City's decision to work with the vendors selected for small purchases and simplified acquisitions. This will be done to verify that all vendors, even when bids are not required, were retained through appropriate methods. A procurement policy that outlines the City's procedures and conforms to applicable federal, state, and local laws will be developed and taken to the Common Council for approval. Suspension and Debarment All vendors who participate in the project will receive a Suspension and Debarment Certificate provided by the City that must be signed by a representative of the vendor and filed with the vendor's contract or in the project folder. Anticipated Completion Date: December 23, 2025

Corrective action plan to address finding 2024-002 – No Written Procurement Policy The following steps will be taken to bring the Authority into compliance. 1. A draft policy will be developed by the manager 2. The draft policy will be shared with Authority members in November 3. At the next Authority meeting (12/8/2025) the policy will be formally presented for adoption. 4. The policy will be effective upon completion of the vote at the December meeting.

Federal Procurement Regulations Planned Corrective Action: Heartland Alliance Health developed and implemented a comprehensive Procurement Policy to ensure full compliance with federal Uniform Guidance requirements. The policy outlines required procurement methods, approval thresholds, documentation standards, and procedures for competitive bidding, price analysis, and sole-source justifications. The policy was reviewed and approved by the Board of Directors (October 2025) and is now in effect organization wide. Person Responsible for Corrective Action Plan: Steve Knox, Controller Anticipated Date of Completion: Resolved

The City of Royal City is committed to meeting all federal grant requirements and thanks SAO for providing guidance regarding this matter. We will proceed with developing written procurement procedures for purchases, services and public works contracts. It is our goal to ensure all stipulations are met for solicitation and award of Architectural and Engineering Services and Public Works contracts as required by state and federal granting agencies.

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding. The Puerto Rico Department of Education (PRDE) acknowledges that the requested procurement documentation was not fully available at the time of the auditors’ review. However, management made every effort to gather and reconstruct the information for all the selected transactions, and the complete documentation will be available. Furthermore, the PRDE is taking actions to improve the accessibility and organization of procurement files to ensure that all documentation is readily available for review in a timely manner. Internal controls over document retention and filing procedures are being reinforced to prevent recurrence of this situation. It is important to note that the procurement processes followed by the PRDE comply with the applicable requirements established under the Code of Federal Regulations (2 CFR Part 200 – Uniform Guidance). Management remains committed to strengthening its internal controls, ensuring full compliance with federal and state requirements, and maintaining complete and timely documentation to support all procurement activities. IMPLEMENTATION DATE Current Fiscal Year. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director

Financial leadership of Child Saving Institute Inc. is in the process of developing a new procurement plan that will put the agency in compliance with 2 CFR sections 200.318 and 200.326

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies and procedures to ensure that future awards or contracts with expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Most of the 2024 expenditures were part of contracts that were already in place when the original findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025