Corrective Action Plans

Finding 2024-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: 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. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, a deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2024, the Town did not comply with the required procurement policies and procedures in place as it related to expenses charged to the major program requiring procurement procedures. One of the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78 Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2023-003 Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: CFO Estimated Completion Date: January 2025 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

IBBG will develop and adopt a written procurement policy that is consistent with the Uniform Guidance, 2 CFR §§200.318–200.326, and applicable state and local laws. The policy will outline procurement methods, competitive bidding requirements, conflicts of interest, and documentation standards. In addition: • A draft policy will be prepared by the I Be Black Girl leadership, the finance committee, and D&K Financial LLC. • The Board of Directors will adopt the final policy. • Training will be provided to staff involved in procurement to ensure consistent implementation of the procurement process.

Management Response: The Organization will establish a procurement policy in 2025. Anticipated Completion Date: 12/31/2025 Responsible Party: Board of Directors

United States Department of Agriculture Federal Assistance Listing #10.855 Distance Learning and Telemedicine Grants United Stated Department of Treasury Federal Assistance Listing #21.029 COVID-19 Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Finding Summary: During the course of the engagement, it was identified that the Cooperative does not have a written policy that addresses the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Mark Vosacek Finance Manager Corrective Action Plan: The Cooperative will modify its written procurement policy 322 to include the requirements of 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: December 31, 2025

FINDING 2024-002 Material Weakness-Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Brittany Couse Contact Phone Number: 765-677-2014 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Clerk Treasurer's Office will continue to check the System for Awards Management quarterly to verify any contractor is not debarred. Further, the office will now check for contracts that exceed the $25,000 threshold that require such inquiry. Anticipated Completion Date: Immediate

Professional and Cultural Exchange Programs - Citizen Exchanges - Assistance Listing No. 19.415 Recommendation: We recommend that the Foundation review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: American Institute For Foreign Study Foundation, Inc. does not agree with the finding. During a visit by representatives of BEGA the existing procurement policy was shared with those representatives. They approved of it and did not recommend any changes. However, a compliant policy that complies with CFR sections 200.318 through 200.326 will be developed. Name of the contact person responsible for corrective action: James Mahoney, CFO Planned completion date for corrective action plan: August 31, 2025

Item: 2024-001 Assistance Listing Number: 21.027 Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Arizona State Office of the Governor Pass-Through Grantor Identifying Number: Unknown Award Year: January 1, 2022 to December 31, 2024 Criteria: In accordance with 2 CFR § 200.318 - General procurement standards - the entity must use its own documented procurement procedures which reflect applicable. State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR § 200.318. Condition: The Organization’s procurement policy and related procedures do address the provisions of 2 CFR § 200.318; however, the Organization has not retained documentation to support that the policy is being adhered to. Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: December 31, 2025 Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will revise its internal control procedures to ensure that documentation is retained to support adherence to its own procurement policy.

2024-005 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: There is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and have taken steps to strengthen compliance with procurement policies. We have established additional documentation requirements for all procurements, ensuring that each transaction clearly reflects adherence to policy, including vendor selection rationale and approval workflows. Procurement policies are being updated to incorporate explicit internal controls and approval processes. Staff involved in procurement will receive guidance on these updated requirements. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2025

Corrective Action Taken Management concurs with the finding. The Organization transferred $151,099.42 from its operating funds back into the SFSP program account prior to the financial statements being available to be issued, thereby restoring the unallowable charge. Additionally, to prevent recurrence, the Organization obtained competitive bids and received approval for a written payroll services contract before June 2025, in advance of the start of the camp season (i.e. the Organization’s operating period). This process was conducted in accordance with federal procurement requirements. Planned Ongoing Corrective Action: The Organization has strengthened its procurement and contract approval procedures to ensure all future contracts funded by the SFSP are subject to competitive bidding, documented in writing, and approved by the State agency prior to charging costs to the program. Responsible Official: Chaim Mendel Friedman, Camp Program Administrator, is responsible for overseeing corrective actions and ensuring compliance with procurement standards and cost allowability requirements. Completion Date of Corrective Actions: Corrective actions were completed prior to the date the financial statements were available to be issued, with continuing oversight in subsequent program years.

Item: 2024-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agency: State of Arizona, Office of the Governor Compliance Requirement: Procurement, suspension and debarment Criteria or Specific Requirement: In accordance with 2 CFR § 200.318 – Procurement Standards, the Association is required to maintain records to sufficiently detail the history of each procurement transaction, including the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The Association did not retain documentation regarding the procurement procedures performed over one of the vendors tested. Name of Contact Person: Debbie Hann, Interim CEO Phone Number: (602) 306-4000 Anticipated Completion Date: February 2026 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. To address the auditor’s recommendation, ASBA will update its policies and procedures to ensure compliance with 2 CFR § 200.318. This will include implementing a formal procurement process with clear guidelines for competitive bidding, documentation, and approvals. Management will also establish a system to monitor procurement activities regularly, ensuring ongoing adherence to the updated policies and regulations.

Contact Person – Pattie Solberg, City Auditor Corrective Action Plan – The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date – December 1, 2025

FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings of this report. Description of Corrective Action Plan: The County Highway Department has implemented a new filing system to help ensure that audit documentation is being maintained for all federal requirements. The County will maintain documentation of all bids and Letter of Interests (LOIs) received from vendors for each project for review. These files are maintained in their own folder with the DES# and project description on the outside. The County will also maintain documentation of the LPA Selection Review Checklist for each project for review. The County Highway Superintendent is responsible for maintaining all the files and the administrator will review/sign the checklist to ensure all the files are properly maintained. In addition, the County is currently working with the County's attorney to develop a procurement policy that includes federal regulations. Anticipated Completion Date: September 2025

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: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The town attorney will draft a standard contract that will apply to any contractors that are paid $25,000.00 or more from federal funds, prior to entering a covered transaction ensuring that their respective contractor is not suspended or debarred. The council president will review and sign the contract ensuring the suspension and debarment clause is included in all respective contracts. The town has put controls and procedures in place to ensure timely documentation of suspension and debarment checks in regard to federal awards. For purchases procured outside of a contractual agreement, the town will require all vendors to self certify prior to entering into a transaction. The town will implement a procurement policy that conforms to the current requirements of CFR 200.318 for micro-purchases, under $10,000.00, the disbursing officer will only require board approval. For small purchases, between $10,000.00 and $150,000.00, three quotes must be obtained and a contract awarded. For purchases that exceed the simplified acquisition threshold, the town must allow for full and open competition in the form of a sealed bid process and awarding a contract. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Urban Development 2024-002 Continuum of Care – Assistance Listing No. 14.267 Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in the procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address this finding Share & Care House is developing and adopting a Suspension and Debarment Policy. The policy requires verification that all vendors, contractors, and subrecipients with transactions totaling $25,000 or greater have not been suspended or debarred from participation in federal programs before entering into a covered transaction. Verification will be conducted by checking the System for Award Management (SAM.gov) Documentation of the verification will be maintained in procurement and contract files. Name(s) of the contact person(s) responsible for corrective action: Celina McKenney Planned completion date for corrective action plan: 10/15/2025 If the Department of Housing and Urban Development has questions regarding this plan, please call Celina McKenney at 253-840-3402 ext. 772. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in the procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: [Describe action planned or taken]. Name(s) of the contact person(s) responsible for corrective action: [Insert name] Planned completion date for corrective action plan: [Insert date] If the [Cognizant or Oversight Agency for Audit] has questions regarding this plan, please call [Insert name] at [Insert Telephone Number].

Finding ref number: 2024-001 Finding Caption: The District did not have adequate written internal controls in place to ensure compliance with federal procurement requirements.Name, address, and telephone of District contact person: Jeff Alderson 186 Iron Horse Court Suite 100 Yakima, WA 98901 509-453-8702 Corrective action the auditee plans to take in response to the finding: This was the Districts first experience with federal funding. We have practiced appropriate internal controls but neglected to have a written formal policy. Upon realizing that we needed a formal written policy we drafted the steps we utilized to procure our contractor and supplies. That draft was then brought through our commissioner’s approval process. It was accepted formally by our Board of Commissioners on May 2024. Anticipated date to complete the corrective action: Completed May 2024

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional procurement policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

Finding Number: 2024-003 Finding Title: Procurement, Suspension, and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Lisa DeBoer – Director of Business Management Jenny Severson – Fiscal Officer Tiffany Bailey – Fiscal Officer Corrective Action Planned: The planned corrective action is to improve and update the agency guidelines and policy for procurement and implement a process with supporting documentation that ensures federal requirements are met. Anticipated Completion Date: November 30, 2025

Finding Number: 2024-002 Anticipated Completion Date: 10-31-2025 Responsible Contact Person: Mark Bridenbaugh, CEO Planned Corrective Action: The organization does have an existing Procurement Policy that is compliant with 2 CFR Section 200.320 for federal grant expenditure related procurement methods. This policy will be reviewed with all Officers, Directors and fiscal staff who are involved in managing any grant program or related purchases. Review and training will occur within the next month. Proper documentation, consistent with the policy, must be reviewed and approved by the CEO, CFO or designee prior to the purchase being made. Documentation will be kept by both the grant Project Director and the approving official.

FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has a longstanding contractual relationship with an engineering firm with extensive knowledge of the City’s water department. The city has put controls and procedures in place to ensure services are bid where federal awards are involved and the dollar amount of such services is expected to exceed the simplified acquisition threshold. The City will review its procurement policy and amend where necessary to conform to the current requirements of CFR 200.318. The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. Anticipated Completion Date: January 1, 2026

FINDING 2024-001 Finding Subject: Department of Transportation Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Brad King Contact Phone Number and Email Address: 765-648-6171 bking@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. The City has implemented procedures to ensure the proper documentation of quotes taken where applicable. Anticipated Completion Date: September 1, 2025

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the federal program: • One instance where the Cooperative followed a bid process, however, the documentation was not retained to support the selection. Additionally, the contract with the vendor was missing required contract provisions in accordance with Uniform Guidance. • Two instances where the Cooperative did not follow the procurement process as detailed in the procurement policy and did not have any formal documentation or contract in place with the vendor. • Three instances where the Cooperative entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Corrective Action Plan: We plan to review our procurement policy with all parties that may enter into contracts for the cooperative to be sure the policy reflects our needs and that procedures are being followed. We will also implement a review process where management signs off on bid selection documentation, including verification that vendors are not suspended or debarred. Responsible Individuals: Hollee McCormick, General Manager and Jason Troendle, Director of Operations and Engineering Anticipated Completion Date: November 2025

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 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: 2024-004 Finding caption: The city did not have adequate internal controls and did not comply with federal procurement requirements. Name, address, and telephone of City contact person: Lisa Wolff, Finance Director PO Box 128 Longview, WA 98632 (360) 442-5036 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). In response to the issues identified, the city is taking the following steps: 1. Rewriting Procurement Manual o The city passed a resolution in August to update the city’s procurement policy. The new policy will include flow charts and links to Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and applicable RCWs to ensure the City is following required procurement processes. The procurement policy updates are expected to be completed by the end of 2025. 2. Checklist Creation o The city will create a checklist as part of the procurement policy. This checklist will guide city staff through the proper processes and document the steps taken. Status of Identified Errors • The agreement with the organization currently operating the city’s homeless shelter is expiring in the near future. The city is currently going through the bidding process for a new operator. Conclusion The City acknowledges that the procurement policy was not followed upon receipt of grant funding. The City is working on new policies and procedures that will ensure that proper procurement processes are followed moving forward. Upon completion of the updates to the procurement process, the City can supply a copy of the new process at your request. Anticipated date to complete the corrective action: No later than December 31, 2025

To address this finding, AACC will adhere to the financial policies and procedures properly documenting procurement decisions for goods and services with a total cost of $25,000 or greater. (Financial Policies and Procedures, pages 25, 45). In the event of “Sole Service Providers”, staff will document the circumstances as such for recording. Effective immediately, all projects will be reviewed by a team assembled within the association, (Staffing to be determined by the President/CEO). A staff member, housed in the President’s Office with research and using a scorecard, assess and present potential opportunities to the President/CEO for approval to proceed. Approved opportunities will be reviewed by the team along with the department head making the request. There will be a collaborative effort of the scope of the project along with the budget necessary to implement the project. All parties will sign-off on their respective steps prior to the full package being presented to the President/Chief Executive Officer for final approval. A checklist will be used to monitor the process. All vendors written into the agreement will be vetted through a process that will include the rationale for their selection.

Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original intergovernmental agreement (IGA) and determined that the agreement had not expired and required no additional board approval or agreement. This is why each year since, Legal has provided authorization for purchase order creation and payment to Chicago Police Department (CPD). The agency is working with CPD to formalize a new IGA. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025