Corrective Action Plans

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

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

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

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

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

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

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

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

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

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

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

The College acknowledges the repeated finding and recognizes the need to strengthen internal controls and documentation procedures to ensure compliance with applicable federal procurement requirements and the RMI Procurement Code. During FY2025–FY2026, the College continued implementing corrective measures to improve procurement compliance and record retention. These efforts include the use of an upgraded cloud-based filing system to ensure proper documentation, organization, and accessibility of procurement records. The College has also strengthened oversight through the recruitment of additional Procurement and Accounts Payable personnel to improve compliance monitoring and accountability. The College continues to review and strengthen its procurement policies and procedures to ensure compliance with federal requirements, including proper vendor quotations, competitive procurement, sole-source justifications, documentation of vendor selection, and verification of suspension and debarment status. Additionally, periodic staff training and improved supervisory review will continue to reinforce compliance with procurement requirements. The College will also review the identified questioned costs and determine whether additional supporting documentation or corrective actions are necessary. These ongoing efforts are intended to strengthen procurement compliance, improve accountability, and prevent recurrence of similar findings in future audits.

As requested, Management provides the following responses to the audit findings for the fiscal year ended December 31, 2024. The Organization acknowledges the findings and is committed to strengthening internal controls, improving compliance with Uniform Guidance requirements, and enhancing oversight of federal award expenditures. 1. Use of Inappropriate Procurement Methods Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management concurs with the audit finding that procurement methods exceeding applicable thresholds were not consistently followed in accordance with established procurement policies and Uniform Guidance requirements, despite the existence of a formal written procurement policy. This issue was primarily due to inconsistent awareness and application of procurement requirements among staff and supervisors across multiple program sites. In addition, there was no standardized verification step within the procurement workflow, and supervisory oversight was not consistently applied. This finding represents a repeat issue from prior year finding 2023-001. Corrective Action Plan - Management has implemented and will continue to strengthen the following controls: - Mandatory training on federal procurement requirements under 2 CFR §§ 200.318 200.326 for all staff involved in purchasing activities. - Implementation of a standardized procurement workflow requiring documented approval and verification prior to purchase execution. - Strengthening supervisory oversight and monitoring of procurement activities across all program sites. - Centralized retention of procurement documentation to ensure completeness and audit readiness. These corrective actions were initiated beginning October 10, 2025, and will be fully integrated into all future grant-funded operations. 2. Conflict of Interest Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management acknowledges the observation regarding a potential conflict of interest involving an individual engaged to oversee fiscal operations under the federal grant. The individual was selected through a delegated implementation group and included in budget approval discussions based on qualifications, experience, and trusted standing within the organization and community. Compensation was established at a minimal rate relative to the fiscal agent budget. However, Management recognizes that the circumstances created the appearance of a conflict of interest, and that adequate written disclosure and recusal documentation were not maintained. Corrective Action Plan - Management will implement the following corrective measures: - Adoption of a formal conflict of interest policy aligned with 2 CFR § 200.318(c)(1). - Annual conflict of interest disclosures for all board members, staff, and grant-related personnel. - Mandatory written recusal procedures for individuals with actual or potential conflicts of interest. - Formal documentation and retention of all disclosures and recusals in compliance files. These procedures will be implemented for all current and future federal awards. 3. Failure to Reasonably Consolidate Procurements Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management acknowledges that procurement activities across multiple program sites were not consistently consolidated, resulting in fragmented purchasing and missed opportunities for cost efficiency. This occurred due to the decentralized structure of operations, lack of centralized procurement oversight, and absence of a formal process to identify and aggregate similar purchases across locations. Corrective Action Plan - Management will implement the following improvements: - Establishment of a centralized procurement function to oversee all purchasing activities across program sites. - Implementation of procurement planning procedures to identify and consolidate similar purchases in advance. - Use of technology systems to track, monitor, and aggregate procurement activity across all sites. - Assignment or hiring of personnel with procurement expertise to provide oversight and training.

Audit Finding Number 2024-005 Audit Finding Title Procurement and Suspension and Debarment Planned Corrective Action Effective September 2026, procedures were put in place for each subgrantee or anyone being paid over $25,000 using federal funds to complete an attestation and submit their internal or audited financials before we contract with them. This will ensure that they have the financial ability to carry out the agreed upon work. We also perform our own verification of their suspension and debarment status. Their Year 4 contracts include a certification that they have not been suspended or debarred and that they are required to inform us if that status changes. We are also in the process of implementing a procurement policy related to federal funding. This policy will be fully implemented by December 2026. Name(s) and title(s) of contact person(s) responsible for corrective action Kim Cockerham, Sr. Director of Finance and Accounting Michelle Swittenberg, EVP of Enterprise Operations

Views of Responsible Officials: The Town and School Department respectfully disagree with the conclusion that sufficient procurement documentation was not maintained for the project identified in the finding. The project referenced was a renovation of the culinary classroom at Carver Middle High School, a portion of which was funded using ARPA resources. The School Department followed a traditional design-bid-build procurement process and believes the project was conducted in full compliance with the applicable requirements of M.G.L. Chapter 149. Subsequent to the issuance of the draft finding, the School Business Office confirmed that comprehensive procurement records are maintained for this project, including: • Designer procurement and RFQ documentation; • Advertising and public posting records; • Invitations for Bids (IFB); • Filed sub-bid documentation; • Bid tabulations and award records; • Executed contracts; • Required bonds, certifications, and contract compliance documentation; and • Other supporting procurement materials. The School Department maintains both electronic and original hard-copy records for the project and has indicated that these materials are available for review. The Town understands that not all documentation may have been requested from, or reviewed with, School Department personnel during the audit process. Corrective Action Plan While management believes the procurement process complied with statutory requirements, the Town recognizes the importance of ensuring that all supporting records are readily accessible during future audits. To strengthen communication and documentation retrieval procedures, the Town will: 1. Establish a formal process for coordinating audit requests with all departments, including the School Department; 2. Maintain centralized tracking of procurement and grant-funded project documentation; 3. Ensure that supporting records maintained at the departmental level are identified and made available during future audit examinations; and 4. Continue training personnel on documentation retention requirements for construction and grant-funded projects. Management believes these steps will improve the efficiency of future audits while continuing to ensure compliance with all applicable procurement laws and regulations.

County Judge/Executive’s Response: The County respectfully disagrees with this finding. The vendor is the only licensed and authorized [name redacted] vendor serving Central Kentucky. Following identification of this matter during the audit, the County issued a bid for the maintenance agreement in FY26. [Vendor name redacted] was the only respondent to the solicitation, further supporting its status as the sole qualified vendor capable of servicing the system. The County has maintained a 13-year working relationship with [vendor name redacted] for this system, and this matter has not previously been identified as an audit finding. Documentation of the original bid opening is available from October 22, 2013 Fiscal Court meeting where the products were public bid and followed all applicable procurement procedures. No unauthorized award occurred. The County utilized alternative statutory advertising procedures and published required notices in accordance with applicable law. While the County understood that publication in one newspaper satisfied the requirement, notices were published in two newspapers to ensure broader public notice and transparency. The audit team acknowledged that this approach provided enhanced transparency. This interpretation was consistent with practices utilized by other jurisdictions. This interpretation was based on the County’s understanding of applicable requirements at the time of publication.

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Contact Person – Katie Greenwood, Deputy Finance Director Corrective Action Plan – Project management staff has been made aware of this requirement and will document vendor checks for federal projects going forward. Completion Date – December 31, 2025

Corrective action taken On June 2, 2025, the Board approved revised Policy F2.01 v.01, Procurement for Product or Services, which requires competitive proposals for contracted services, documented selection criteria, and retention of bid responses and award decisions. Effective September 1, 2026, C-WHO adopted Procedure SOP F2.01 v.01, Procurement Under Federal Awards, approved by the Chief Executive Officer and the Director of Finance. The procedure supplements Policy F2.01 v.01 and applies to any purchase charged in whole or in part to a federal award. SOP F2.01 v.01: • incorporates 2 CFR 200.317 through 200.327 and Appendix II to Part 200, as adopted by HHS at 2 CFR Part 300; • sets procurement methods by the current federal thresholds (micro-purchase, small purchase with at least three written quotes, and sealed bids or publicized proposals above the simplified acquisition threshold); • limits noncompetitive procurement to the circumstances in 2 CFR 200.320(c), documented on a Sole Source Justification form approved before commitment; • requires SAM.gov exclusion verification before any covered transaction of $25,000 or more (2 CFR Part 180), and an LEIE check for health care service providers; • establishes written conflict-of-interest standards, including disclosure, recusal, and disinterested Board approval for related-party procurements; • requires cost or price analysis above the simplified acquisition threshold and documented price reasonableness for all federally funded purchases; • requires a Federal Procurement Checklist, completed by a preparer and signed by a separate reviewer, before a contract is signed, a purchase order is issued, or federal funds are charged; and • credits discounts and rebates on federally funded purchases to the award under 2 CFR 200.406.

The Institute will adopt written procurement policies and procedures that conform to the Uniform Guidance procurement standards, present them to the Board of Directors for approval, and train the personnel responsible for procurement on their use. Anticipated completion date: December 31, 2026. Responsible contact person: Kathy Walker, Executive Director.

Finding 2024-005 – Lack of Written Policies Required by the Uniform Grant Guidance Contact Person: Gary Kloosterman, Village Manager Planned Corrective Action: The Village will develop and adopt written policies and procedures to comply with Uniform Guidance requirements, including internal controls, procurement, cash management, and allowable costs. Anticipated Completion Date: March 31, 2026

AIRS management has started the process of creating new and updated policies and procedures related to financial reporting activities, including written procurement standards, written standards of conflict of interest, and others as required under Uniform Guidance.

Management agrees with the finding. Management has downloaded 2 CFR Part 200, section 200.318(i) for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

Procurement and Suspension and Debarment Public Housing Operating Fund – Assistance Listing No. 14.850 Recommendation: We recommend that the Authority designate an individual to maintain and retain all procurement documentation (including RFPs, addenda, contracts, cost analyses, and SAM exclusion searches) in a centralized file for each vendor, and to review each covered transaction prior to contract execution to confirm that suspension and debarment verification has been performed and documented in accordance with 2 CFR Part 200, Subpart D and 2 CFR Part 180. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2025, the HA hired the financial consulting firm of Kubas Keller and Associates. They have vast experience with HA’s all around the country and will work with the Mod Dev Coordinator and the Purchasing Manager to ensure that all vendor documentation regarding procurement is in a centralized file for each vendor and to properly review each file prior to awarding the work. Name(s) of the contact person(s) responsible for corrective action: Tony Palmer, CPA Kubas Keller and Associates Planned completion date for corrective action plan: April 2025.

2024-005 - LACK OF SUPPORT FOR PROCUREMENT-ALN 12.118 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: The City of Cando did not maintain support surrounding the selection process for the construction engineer for the 2022 Water and Improvements project. Therefore, we were unable to determine if the engineer selection was properly completed. In addition, the City of Cando did not have a procurement policy. Management's Response: We Agree. The City will ensure future procurement documentation for construction engineering services is maintained. Anticipated Completion Date: 2026