Corrective Action Plans

Views of responsible officials and planned corrective actions - Management concurs with the audit findings and plans to review and implement additional internal policies and procedures related to procurement and suspension and debarment protocols for grant funding in future periods.

FINDING 2024-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Anticipated Completion Date: December 2026

Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2023-003) and current year renumbered recommendation (2024-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h); and development of a comprehensive Health Resources & Services Administration (HRSA) group of related policies and procedures. A. Financial Policies – May 2025. While the Organization initially prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024, by May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Simultaneous to the policy work described above, several processes to guide and align procurement practices, throughout the Organization, was initiated, including the use of MTPF, Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal, and to date implementation of the processes continue. C. HRSA Policies – July 2025. By July 2025, the Organization developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. In August 2025, the Board was provided policies developed within the Organization’s policy framework, including the above policies. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.

Procurement procedures have been reiterated with staff members and enhanced to include quotes and bids as necessary. Responsible Official: Director of Finance Expected Completion Date: Completed.

Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

Management's Response: AMHE has Established for the Aha Macav Housing Entity by Board action on December 28th, 2017. The effective date of this Statement is December 28th, 2017. This Statement of Procurement Policy complies with the Native American Housing Assistance and Self Determination Act of 1996, as amended, and the implementing regulations at 24 CFR 1000, 24 CFR 1003, and the procurement standards of 2 CFR 200. AMHE will adhere to the Procurement Policy hat has been established and clarify the process so that no steps are skipped in the process moving forward. Estimated Completion Date: Immediately AMHE will adhere to the Procurement Policy currently in place. This will be addressed with AMHE staff prior to 6/30/26. Responsible Party: Maintenance Supervisor, Comptroller and Interim Director.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Views of Responsible Officials and Planned Corrective Actions: ATS has drafted an organization-wide procurement policy to ensure it includes all the Uniform guidance procurement elements. The draft will be reviewed by senior management for comment prior to formal issuance.

Finding 2023-005 ● Condition: There are no written policies and procedures for allowable costs/cost principles, cash management, procurement and suspension and debarment requirements. ● Cause: The Organization does not have a process for reviewing their accounting policies and procedures manual on a regular basis to ensure written procedures conform to Uniform Guidance requirements. ● Corrective Action Plan: Management agrees with the finding and they will evaluate our findings to determine an appropriate corrective action. Financial policies and procedures will be created and implemented. Annual schedule of expenditures will be created by Executive Director or Bookkeeper and reviewed by Board of Directors. Contact Person: Kirsten Jurcek Anticipated Date of Completion: September 1, 2026

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Passed Through Payments from the State of New Hampshire Department of Environmental Services Corrective Action Plan: The District will draft a procurement policy which conforms to the requirements set forth in the Uniform Guidance, specifically addressing the requirements of 2 CFR § 200.318 through 200.327. Individual Responsible: Roland Seymour, Commissioner Arthur Demass, Commissioner Steve Partridge, Commissioner Anticipated Implementation Date of Corrective Action: May 2026.

Finding 2024-002 Procurement, Suspension and Debarment Material Weakness in Internal Control Over Compliance and Instance of Material Noncompliance Assistance Listing 21.029 Wabash is currently in the process of formalizing its procurement standards and internal controls. While we previously managed contractor selections through established internal practices, we recognize the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash will implement a formal Procurement Policy and Procedure by June 30, 2026. This document will mandate: • Standardized Selection Criteria: Clear guidelines for the evaluation and selection of contractors to ensure transparency and competition. • Debarment Verification: A required protocol for verifying and documenting that contractors are not excluded or debarred via the System for Award Management (SAM). • Oversight: The Network Operations will be responsible for the implementation and ongoing monitoring of these controls to ensure full regulatory compliance. These measures will ensure that all future procurement activities meet federal requirements and organizational standards for financial integrity. Contact person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer

Management acknowledges that procurement documentation was not consistently maintained during the audit period. Since that time, improvements have been made; however, additional work is ongoing to fully standardize documentation practices across the Organization. Staffing stability since September 2024 has improved consistency and accountability. A Vice President of Programs has been hired to strengthen compliance oversight, and a Compliance & Risk Management Committee will be established in FY2026 to support organization-wide monitoring. The Organization is also implementing targeted training on 2 CFR Part 200 for fiscal, program, and contracts staff to reinforce procurement requirements. In addition, enhancements to procurement procedures and documentation standards are underway. The implementation of Blackbaud Financial Edge in FY2027 will further strengthen internal controls through improved workflows, tracking, and documentation retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken - Reinforced procurement documentation expectations with program and administrative staff - Increased supervisory review of procurement transactions - Hired a Vice President of Programs to strengthen compliance oversight - Established plans to launch a Compliance & Risk Management Committee in FY2026 - Initiated cross-functional training on 2 CFR Part 200 for fiscal, program, and contracts staff - Began enhancing procurement policies, procedures, and documentation standards - Initiated implementation of Blackbaud Financial Edge to support procurement tracking and internal controls.

The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The City will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

The City will develop written standards of conduct that satisfy the requirements of 2 CFR § 200.318(c)(1).

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The policy was revised at the end of the 2025 Fiscal Year. Additionally, a new and additional review process was put into place prior toentering a requisition for approval. This process requires all necessary documentation be furnished to the finance office prior to the requisition being approved. Completion Date: 7/16/2025

2024-004 Improve Internal Controls Over Procurement Federal Agency: Department of the Treasury Award Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: 2024 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria: Per 2 CFR 200.318–200.327, non-federal entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards set forth in the Uniform Guidance. For purchases exceeding the micro-purchase threshold, procurement must include documented procedures, full and open competition (unless an exemption applies), and executed contracts. All contracts must be fully executed and amendments provided for any changes to terms or scope. Additionally, any exemption from competitive bidding must be documented, and only applies to the period and scope approved. Suspension and debarment checks must also be performed and documented for covered transactions with vendors. Condition: During our testing of one procurement transaction under the SLFRF program, the Town received an exemption from bidding requirements typically required under Massachusetts’ state law. The exemption was due to an initial emergency procurement; however, expenditures continued to be incurred after the initial emergency ended and the associated contract’s substantial completion date. The Town did not provide contract amendments to extend the contract, nor did it perform additional procurement procedures for expenditures that occurred after the emergency period ended and outside the scope of the exemption. In addition, the contract with the vendor was not countersigned by the Town and therefore a fully executed contract did not exist. Further, suspension and debarment checks for vendors were not retained as required. Cause: The Town did not ensure contracts were fully executed prior to commencement of work, did not maintain documentation or perform procurement for additional expenditures incurred after the completion date of the original contract and outside the scope of the emergency exemption, and did not maintain documentation of required suspension and debarment checks. Effect: Failure to obtain a fully executed contract, perform and document suspension and debarment checks, and appropriately document or procure additional services beyond the contract term increases the risk of noncompliance with federal procurement requirements and may expose the Town to possible unallowable costs, conflicts of interest, or ineligible vendor participation. Recommendation: The Town should implement policies and procedures to ensure all contracts are fully executed prior to work commencement, and any extensions or additional services beyond the original contract are properly documented via contract amendments or appropriate procurement methods in accordance with Uniform Guidance. The Town should also ensure continued monitoring and documentation of procurement exemptions and maintain documentation of all suspension and debarment checks for vendors paid with federal funds. Views of Responsible Official: The Town implemented a purchasing policy to ensure compliance with federal awards required under the uniform guidance. The adopted policy addresses the concerns identified in 2024-004.

AEA agrees with the finding. Management acknowledges that, while the organization followed procurement guidance contained in the Weather Assistance Program Policies and Procedures Manual, it did not formally adopt an organization-wide written procurement and suspension and debarment policy fully compliant with 2 CFR Part 200.317–200.327. AEA will formally adopt a written procurement policy that incorporates all applicable Uniform Guidance requirements, including procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and procedures for suspension and debarment verification for covered transactions. Management will also implement related procedures and control documentation to support consistent application of the policy across federally funded programs. AEA will provide training to relevant personnel and will maintain documentation evidencing procurement review and suspension/debarment verification, where applicable. Management believes these corrective actions will bring the organization into compliance and reduce the risk of future noncompliance.

Finding Number: 2024-003 Planned Corrective Action: Medina County acknowledges the deficiencies identified related to procurement documentation and suspension and debarment compliance under the Federal Transit Cluster. To address these issues, the County has implemented the following corrective actions: 1. Suspension and Debarment Verification Controls Effective immediately, prior to execution of any covered transaction funded in whole or in part with federal funds that is expected to equal or exceed $25,000, the Transit Department will verify vendor eligibility by performing a search of the System for Award Management (SAM.gov). Evidence of the SAM search, including the date performed and results, will be retained in the procurement file. In addition, all federally funded procurement contracts will include a standard suspension and debarment certification clause, or alternatively, a signed vendor certification will be obtained and retained when applicable. 2. Standardized Procurement Documentation The County will implement a standardized procurement checklist to be completed for all Transit procurements. This checklist will require documentation of: o The rationale for the method of procurement o The basis for contractor selection or rejection o The selection of contract type o The basis for contract price Completed checklists and supporting documentation will be maintained as part of the official procurement file in accordance with 2 CFR § 200.318 and the Medina County Transit Purchasing Policies and Procedures Manual. 3. Supervisory Review and Oversight The Transit Director, or designee, will perform a documented supervisory review of each procurement file prior to contract execution to ensure all required federal and County documentation is complete. No procurement will proceed without evidence of this review. 4. Training and Accountability Staff involved in Transit procurement activities will receive refresher training on federal procurement requirements, including suspension and debarment and procurement documentation standards. Compliance with these procedures will be monitored on an ongoing basis. Anticipated Completion Date: Implemented immediately and fully operational by March 31, 2026 Responsible Contact Person: Shannon Rine, Transit Director

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

The Organization will develop and implement written procurement policies and procedures that comply with Uniform Guidance and ensure consistent application across all procurement activities.

Audit Finding Reference: 2024-003 Improve Internal Controls Over Procurement Planned Corrective Action: The Town will review and revise its procurement procedures to ensure that federal requirements under the Uniform Guidance are followed for all federally funded transactions. For future federally funded contracts, the Town will maintain documentation demonstrating adherence to Uniform Guidance procurement requirements, including appropriate justifications for exemptions. The Town will ensure program staff are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: February 2, 2026

Audit Finding Reference: 2024-005 Improve Procurement Procedures Planned Corrective Action: The Town will revise its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town will ensure adequate documentation is retained for all federally funded procurements, and that procurement staff and grant managers are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: Management has made staff aware of the Federal procurement requirements associated with Federal grants and will work with grant managers, finance and procurement department staff to ensure this requirement is implemented in fiscal year 2026; on or about March 18, 2026.

Improve Controls Over Procurement Procedures (Material Weakness, Compliance Finding) Planned Corrective Action The District has reviewed procurement procedures related to the Child Nutrition Program and has taken corrective action to ensure compliance with federal procurement requirements under 2 CFR 200.318–200.326. All food service vendors are now procured through appropriate procurement procedures, including competitive solicitation and documentation of vendor selection as required by federal regulations. The District will maintain procurement records including solicitations, bids or quotes received, vendor selection documentation, contracts, invoices, and payment records. The Business Offi ce will work with the Food Service Department to ensure that all future procurements under federal programs follow required federal, state, and local procurement standards. Staff responsible for procurement will be reminded of documentation and competitive bidding requirements. Procurement documentation will be periodically reviewed by the Business Offi ce to ensure ongoing compliance. Name of Contact Person and Completion Date Nancy J. Konisky, Business Manager Completion Date: Implemented March 1, 2026