Corrective Action Plans

Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Recommendation: Management should draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the recommendation noted above by May 31, 2025.

The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the procurements. The District will assign someone in the District office to review procurement requirements and ensure contracts meet the District’s policies. Shannon Grindell, Susan Mayer Ongoing

Views of Responsible Officials and Planned Corrective Action The County has a written policy regarding Federal Grants that was passed by the Grant County Commissioners in January 2025. Finding resolution timeline: Resolved. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager

Federal Agency Name: U.S. Department of Treasury Assistance Listing Number(s): 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Finding Summary: Non-Federal 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. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the Non-Federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. It was noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Responsible Individuals: Kyle Wilmot Canyon County Controller Corrective Action Plan: Members of the audit office will review each vendor in the SAM.gov database to ensure that they are not suspended, debarred or otherwise excluded. The search of these entity(s) will then be saved to the shared drive for the upcoming ACFR season and the supervisor will be notified of the search to ensure that the files have been properly saved. Anticipated Completion Date: Canyon County will complete the corrective actions for the September 30, 2025, reporting period.

Audit Finding Summary: 2024-002 The Organization did not establish or follow sufficient internal controls to ensure compliance with federal procurement requirements, including maintaining the required documentation for procurement activities. Corrective Action Plan: Contact Person Responsible for Corrective Action: Wendi Gephart, Federal Contracts and Grants Compliance Manager wendi@movementstrategy.org | (510) 956-3849 Planned Action: MSC recognizes the need for improved procurement documentation and internal controls. To strengthen compliance with 2 CFR 200.318-326, MSC will take the following actions. Revised Procurement Policies: MSC is updating its procurement policies and procedures to reinforce adherence to federal regulations, ensuring full and open competition in all procurement transactions. Enhanced Documentation and Record-Keeping: A comprehensive process will be established to maintain detailed procurement records, including justification for vendor selection, contract pricing, and competitive bidding results. This will ensure transparency and compliance with federal requirements. Staff Training in Federal Procurement Standards: MSC will provide training to staff on procurement regulations, including conflict-of-interest policies, documentation requirements, and competitive bidding procedures. Periodic Compliance Review: Internal review will be conducted periodically to verify compliance with procurement policies and federal regulations. MSC remains committed to continuous improvement in financial and compliance practices to uphold the integrity of its federally funded programs. Expected Completion Date: June 30, 2025

We will comply with the procurement policy. I have already submitted the information to ODEW for FY25.

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 2024-003 Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2023-003) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Planned Corrective Action: While procurement requirements are followed, management concurs that the documentation of procurement activities does not always occur. The Payables Manager will gather all procurement documentation with the purchase order request, and work with all Operations Directors to ensure proper procurement activities are performed. Michelle Krauter, VP, Chief Financial Officer, will approve all purchase order requests. This documentation will be retained with the approved purchase order and invoices. Michelle will ensure all compliance requirements are followed and appropriately documented.

Procurement and Suspension and Debarment – Clean Water State Revolving Fund – Assistance Listing No. 66.458 Recommendation: We recommend that the organization develop and implement a formal, documented policy for procurement and suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on implementing a formal, documented policy for procurement and suspension and debarment. Name of the contact person responsible for corrective action: Steve Schaefer, Trustee Planned completion date for corrective action plan: Ongoing consideration

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2024-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District has updated its policies and procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The updated procedures include steps so that district personnel are following the requirements of the Uniform Guidance related to methods of procurement and suspension and debarment requirements including maintaining appropriate documentation. Official Responsible – The District’s Director of Finance and Operations, Mark Kumlien Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – The District’s Director of Finance and Operations, Mark Kumlien, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, and suspension and debarment requirements.

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Corrective Action Plan: The Authority acknowledges the finding and is currently working to correct this. Responsible Official: Contact person is Todd Shurn, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2025

CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding Reference Number Corrective Action Responsible Person Anticipated Completion Date Finding 2024-001: Internal Control Over Financial Reporting Because of its size, the City does not feel it is cost effective to hire an additional employee(s) with the experience, technical training and time to prepare its financial statements. Draft copies of reports are reviewed and approved prior to their issuance by management. As such, management will continue to rely on the auditors to assist in preparing the City's financial statements and schedule of expenditures of federal awards and assist with certain year-end adjustments. Blyann Johnson Ongoing Finding 2024-002: Internal Control Environment The City is aware of the lack of segregation of duties caused by the limited size of its staff. Segregation is enhanced whenever possible and the council assumes an active role through monthly review of receipt and disbursement transactions and monthly financial statements. Blyann Johnson Ongoing Finding 2024-003: Significant Deficiency - Internal Control Over Procurement, Suspension and Debarment City personnel will make every effort to familiarize themselves with the rules of the Federal Awards programs. Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Blyann Johnson 12/31/25

Significant Deficiency over Procurement Contact Person Responsible for the Corrective Action Plan: William Roberson, Financial Services Director Corrective Action Plan: The County identified a problem during the fiscal year, corrected the issue during the fiscal year, and shared the information with the audit team. Procurement for the new radio read water meters began with informal solicitation of pricing during the prior administration which ended in February 2023. The lack of formal procurement was identified as an issue by the interim county manager and recommended that the County reject the three informal bids. Subsequently, the County initiated a formal procurement process and is documented in meeting minutes, and a copy of County Administration’s memorandum to the Board of Commissioners was shared with the audit staff early in the audit process. The project was approved and contract awarded on July 5, 2024. Anticipated Completion Date: Completed

Recommendation: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the federal law and standards identified in 2 CFR 200.318 through 2 CFR 200.327. A procurement policy that aligns with these federal requirements is currently being developed. The policy is expected to be adopted and in place in the coming months. Name(s) of the contact person(s) responsible for corrective action: Angela Woods Planned completion date for corrective action plan: June 2, 2025

Management Response: The Mifflinburg Area School District agrees with the finding. The SFA has updated Policy #626 Procurement - Federal Programs. The SFA has removed the RFP reference from the informal procurement method. The SFA reviewed the bidding requirements and will adhere to the policy. This policy was approved by the School Board in May 2024. The SFA has updated future produce solicitations to include the following: Pricing will be a cost-plus fixed fee structure. All prices bid for all products will be net, Free on Board (F.O.B.). SFA will consider individual product price changes both as part of a renewal to the awarded contract and during the contract year. Product price changes may not exceed the U.S. Department of Labor-Bureau of Labor statistics Northeast region not seasonally adjusted consumer price index percentage change annual average for the previous 12 months. Vendors must submit both the supplier charge and the fixed fee, which much be listed separately. Additionally, the SFA implemented a formal requisition process in the Food Service department, in which pricing would be entered into the requisition and verified against the bid or other respective documents, then submitted for approval. The SFA employees responsible were trained in this procedure. Individual Responsible: Superintendent, Business Manager, Food Service Director Anticipated Completion Date: May 31, 2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Name of contact person: Peri Whiteclay Corrective Action: Checking the SAM system was added to the county’s grant management procedures after the audit of fiscal year 2023. Proposed Completion Date: Completed.

Corrective Action Plan We are in the process of updating the Organization’s procurement policy and procedures regarding suspension and debarment requirements. Completion Date Fiscal year end 2025

SIGNIFICANT DEFICIENCY 2024-002 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

Federal Agency: U.S. Department of Agriculture Program/Cluster: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number: 10.557 Pass‐through: California Department of Public Health Award No. and Year: 22-10294 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Condition. One (1) instance out of a population of one (1) where the County did not document the history of the procurement, including the rationale for method of procurement, selection of contract type, basis for contractor selection, and basis for the contract price. Response to Condition Solano County agrees with the auditors finding that the contract lacks documentation of rationale for the method of procurement. The purpose of the contract was to hire a credentialed lactation consultant. Interested contractors would have to possess an International Board of Lactation Consultant Examiners (IBCLC) credential. Documentation provided included three resumes where each contractor possessed the requirement credential and indicated the proposed hourly rate. Although the rationale was not documented, the contractor was selected based on the hourly rate, which was comparable to the County’s salary for a similar classification. Specific Corrective Plan Procedures addressing Condition Solano County will review the County procurement policy and will follow all procedures associated with the policy. Future contract documentation, including emails, will be saved on the share point as PDFs. Responsible Individual(s): Christopher Husing, Senior Health Services Manager, Solano Public Health Anticipated Completion Date: April 1, 2025

Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit finding related to procurement and suspension and debarment compliance under Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program (Federal Assistance Listing Numbers 93.129, 93.527; Federal Award Year 2023-2024). We are committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 2 CFR 200.318 and 2 CFR 180 regulations. Corrective Actions Taken: 1. Established & Implemented Detailed Record-Keeping for Procurement Transactions: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor invoices and procurement transactions in real time and syncs with Sage Intacct, the new accounting software implemented in January 2024. - Detailed records of all federal grant expenditures are maintained in Bill.com and monthly reconciliations are conducted in the general ledger to ensure all procurement transactions are properly classified to their specific grant by their grant ID. 2. Established & Implemented Suspension & Debarment Verification Procedures: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor information including Sam.gov vendor eligibility documentation. - All vendors are verified using Sam.gov. and documentation is kept in the electronic vendor file in Bill.com. This process was implemented in March 2024 and is ongoing. 3. Monitoring - The Finance team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.

Identifying Number: SA 2024-002 Description of Finding: During the audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, "Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval". During the audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During the audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred were performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Corrective Actions Taken or Planned: We are in the process of updating our Procurement Policy. We will ensure that we follow these updated policies and procedures to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

Identifying Number: SA 2024-001 Description of Finding: MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well- defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Corrective Actions Taken or Planned: We have an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. We also have Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. We are in the process of updating our Procurement Policy. We will review and update these policies and/or create new policies to make sure we are compliant with the Uniform Guidance. The updated or newly created policies will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

Federal Award Finding: 2024-002 Material Weakness in Compliance and Internal Control over Procurement and Suspension and Debarment Name and Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH has evaluated the processes and procedures regarding procurement and suspension and debarment, as well as the processes for maintaining records supporting all procurement activity. Management will appoint an individual to oversee this. Proposed Completion Date: June 30, 2025

Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement 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 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 allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No 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. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: October 31, 2024 Responsible Persons: District Board, Umpqua Public Transit District

2024-002 - LACK OF WRITTEN FISCAL POLICIES AND PROCEDURES As of March 27, 2025, scaleLIT has updated its fiscal policies and procedures to reflect all the federal guidelines required by the Uniform Guidance. The scaleLIT Board Treasurer has reviewed and approved the updates.

Corrective Action Plan Procurement – Finding 2024-003 Roof Above will amend the procurement policy to document the criteria for vendor selection, including bids, quotes, and sole source justification and follow the policy when contracting with new vendors using federal funding. Contact person responsible for corrective action: Kaedon Grinnell, Chief Program Officer Anticipated completion date: March 31, 2025