Corrective Action Plans

Finding 2024-001 Condition Quarterly reports submitted were not reviewed by someone other than the preparer. The quarterly reports are both prepared and signed by the Administrative Services Manager. While the information used in preparing the reports is gathered from the City and Black & Veatch (Construction Manager) is detailed and goes through reviews prior to being provided, there is no independent review of the report prior to authorization and submittal. Corrective Action Plan Quarterly reports will continue to have information gathered from the Construction Managers and the City of Waukesha Engineer working on the projects. The Senior Accountant or other appropriate staff member will prepare the quarterly report and the Administrative Services Manager will then review the report, sign it, and submit the quarterly report to the EPA. Name(s) of Contact Person(s) Responsible for the Corrective Action: Cortney Nagel, Administrative Services Manager Anticipated Date of Completion: 09/30/2025

Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2024 COVID-19 - Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material NoncomplianceFinding Summary: During the course of the engagement, it was identified that the Cooperative's written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative did not follow procurement, suspension, and debarment procedures required under the Uniform Guidance prior to entering into contracts with vendors. Responsible Individuals: Director of Administration Services, General Manager Corrective Action Plan: The Cooperative will update its Board Policy No. 205 to include the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative will maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2025

2024-005 Improve Internal Controls Over Procurement Management Response and Corrective Action Plan (DPW): Management concurs with the finding. The City acknowledges that one procurement, a rental for a piece of equipment under the SLFRF program for ARPA Replacement Roads and Sidewalks, lacked sufficient supporting documentation to demonstrate compliance with federal procurement standards. The City is committed to strengthening internal controls to ensure all federally funded procurements comply with 2 CFR 200.317–200.327, Treasury’s SLFRF Compliance and Reporting Guidance, and applicable state and local procurement laws. Planned Implementation Date: 12/17/2025 Person Responsible for Corrective Action: Julianne Pelletier

Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends regular review of the Organization's procurement policies to ensure they continue to meet procurement standards, as set by Uniform Guidance, and they continue to be consistently implemented. CLA also recommends reviewing internal controls surrounding procurements to ensure they are sufficient to prevent noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previous corrective actions were completed in April 2024 upon receipt of our FY 2022 audit and further amended in August 2024 during FY 2023 audit to update internal procurement policies to match Uniform Guidance requirements. We believe these corrective actions would have captured most, if not all, of the incidents in February and March 2024 that contributed to this repeat finding. That said we will continue to regularly review the Organization’s procurement policies to ensure they meet procurement standards. We also aim to implement an annual internal control review to ensure they are sufficient to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/01/2025

Finding 2024-003: Noncompliance – Procurement Policy The entity does not have a documented procurement policy. As a result, there is no formal guidance to ensure that procurement transactions are conducted in accordance with applicable federal regulations, including requirements related to full and open competition, appropriate procurement methods based on dollar thresholds, and verification of suspension and debarment. Planned Corrective Action: Management has developed and put in place a written procurement policy effective May 1, 2025. James Frederick, COO, is responsible for the corrective action plan.

WEST MICHIGAN FOOD PROCESSING ASSOCIATION CORRECTIVE ACTION PLAN DECEMBER 31, 2024 West Michigan Food Processing Association respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit period: Year ended December 31, 2024. District Contact Person: Marty Gerencer, Contracted Executive Director The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding: Federal Awards and Questioned Cost Finding 2024-01 Recommendation: We recommend that West Michigan Food Processing Association develop and implement comprehensive written policies and procedures to address the requirements of the Uniform Guidance. These should be tailored to the Association’s structure and operations and cover all applicable federal compliance areas. Management should also establish a process to periodically review and update these documents to ensure continued compliance. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future. Finding: Financial Statement Audit Finding 2024-02 Recommendation: We recommend implementing a compensating control to mitigate this risk, such as: ➢ Requiring documented approval by a board member or other authorized individual prior to processingdisbursements, or ➢ Providing a board member or finance committee member with view-only online access or automatedbank alerts to review all cleared transactions. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Montesano January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported 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: 2024-001 Finding caption: The City did not have adequate internal controls in place to ensure compliance with federal procurement requirements. Name, address, and telephone of City contact person: Gretchen Sagen, CFO/Clerk 112 N Main Street Montesano, WA 98563 (360) 249-3021 Corrective action the auditee plans to take in response to the finding: To address this finding and strengthen documentation, the City is taking steps to: 1. Adopt a written City procurement policy that incorporates federal, state, and local thresholds and methods, consistent with 2 CFR 200.318–327; and 2. Update our standards of conduct to explicitly include all conflict-of-interest provisions required under federal regulations. These corrective actions will supplement the existing WSDOT oversight framework, provide auditors with clear reference points for internal controls, and ensure continued compliance with Uniform Guidance requirements. Anticipated date to complete the corrective action: October 2025

2024-002: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School's reasoning for a noncompetitive procurement. Repeat Finding: Similar to prior year finding 2023-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Controller's office will provide instruction for all departments on retrieving letters from their vendors. This training is crucial for ensuring compliance with Suspension & Debarment regulations and establishing a robust system of internal controls for federal funds. Anticipated Completion Date: December 31, 2025

Coronavirus Relief Funds – Assistance Listing No. 21.027 Recommendation: CLA recommends the County review and follow their procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Dickinson County will follow their procurement policy related to federal awards. Name of the contact person responsible for corrective action: Brian Bousley, Controller/Administrator Planned completion date for corrective action plan: December 31, 2024

Finding 2024-002 Corrective Action: We will update our procurement policies and procedures to align with the latest Uniform Guidance requirements, including the 2024 updates that mandate documentation of price reasonableness for all micro-purchases. We plan to adopt a standardized coding submission that clearly articulates the various types of purchases and the appropriate documentatoin for each type of purchase. We will adopt regular training sessions for procurement and grant management staff to reinforce comnpliance requirements and proper documentation practices. Person Responsible: Interim CFO - Bruce Tyler and Finance Director - Jason Phillips Timing for Implementation: October 31, 2025

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

The Board of Health will adopt updated written policies periodically in accordance with the Uniform Guidance to help improve internal controls over federal compliance for the findings listed in this number.

Person responsible for this corrective action plan: Jana Kent, Executive Director Corrective Action Plan: YNHA is developing a suspension and debarment training for all staff and program managers to ensure that suspension and debarment requirements are adhered to and include a search on Sam.gov, as required. Estimated Completion Date: October 31, 2025

Finding 2024-004 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2024 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

Contact Person (s): Jim McCarthy - jim@waterwatch.org ; Neil Brandt – neil@waterwatch.org Corrective actions planned: The following corrective actions are being immediately implemented for contracts in WaterWatch’s restoration program in order to achieve compliance: 1. Language requiring all contractors to comply with the Build America, Buy America (BABA) Act is added to all new WaterWatch contracts and all current contracts via amendment. 2. Language requiring all contractors to comply with federal suspension and debarment contracting standards is added to all new WaterWatch contracts and all current contracts via amendment. 3. WaterWatch will keep formal documentation of debarment searches for all contractors. 4. WaterWatch will keep formal documentation of contractor procurement process in both Southern Oregon and Portland offices. Anticipated completion date: September 1, 2025

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA adopted a new, updated procurement policy in October 2024. PDA worked with Clark Nuber to develop this policy. Anticipated Completion Date: October of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors

Finding 2024-004: Written Policies and Procedures • Planned Corrective Action: We will adopt formal policies and procedures that document our current practices and also meet the requirements of the Code of Federal Regulations (CFR). • Anticipated Completion Date: September 30, 2025. • Responsible Contact Person: Rick Smith, Executive Director

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The following corrective actions will be implemented by the School District: 1. Implement Strengthened Pre-Approval and Documentation Procedures: a. All Child Nutrition purchases will require a completed purchase request form that clearly identifies the funding source, purpose, and allowability under federal guidelines. b. Documentation (invoices, quotes, purchase orders) must be attached and reviewed by the School Nutrition Director and CFO or designee before approval. 2. Enhance Segregation of Duties: a. The individual initiating a purchase or expenditure will not be the same person approving or reconciling it. b. Monthly expenditure reviews will be performed jointly by the Finance Department and School Nutrition leadership to ensure accuracy and compliance. 3. Establish an Internal Monitoring Checklist: a. The School Nutrition Department will implement a monthly internal monitoring checklist that includes documentation review, reconciliation of expenditures, and verification of procurement compliance. The CFO will meet with the Nutrition director monthly. 4. Update Written Polices and Procedures: a. The district's Financial Procedures Manual and the School Nutrition Operations Manual will be updated by December 2025 to reflect all new internal control steps and approval requirements specific to federal expenditures. Estimated Completion Date: June 30, 2026 Contact Person: Tiffany Crockett, Chief Financial Officer Telephone: 478-946-5521 Email: tiffany.crockett@wilkinson.k12.ga.us

Finding 2024-005 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Nate Moore, Finance Director Corrective Action: The Finance Department will regularly ensure that the procurement policy for the City is followed, and will be sure that it is reviewed often to be sure that no modifications or adjustments need to be made. Anticipated Completion Date: June 30, 2026

Reference: 2024-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus Frederickson, Mayor; Patrick Reagan, City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2025

Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: The City does not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Finance Officer Corrective Action Plan: The City will establish controls to follow all applicable procurement requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: December 31, 2025

The executive level, including the finance director of SEVCA, acknowledge these weaknesses in our practice in FY24. SEVCA has renewed focus on well documented proper procurement procedures and accountability for oversight of procurement action steps by multiple team partners. The following corrective actions are in place: 1. Policy Reinforcement and Training o Conducted mandatory training for all staff involved in procurement, emphasizing the documentation requirements outlined in the Organization’s procurement policy.o Distributed updated procurement documentation checklists to ensure clear understanding of required elements for each procurement file. 2. Standardized File Documentation Process o Implemented a standardized cover sheet or checklist for each procurement file to be completed and reviewed before contract finalization. This indicates whether all required steps (e.g., solicitation of bids) were completed or, if not, the reason for deviation in standard practice. 3. Internal Review and Monitoring o Established a quarterly internal review of a random sample of procurement files to ensure compliance with documentation standards. o Assigned a staff member or team (e.g., Finance Support Specialist) to oversee this review process and report findings to Finance Director and Program Director. 4. Follow-Up and Accountability o Require program director and finance director sign-off on all procurement files over $20,000 to ensure all documentation requirements are fulfilled. o Include procurement documentation compliance as part of staff performance evaluations where relevant. Responsible Person: Finance Director, Lisa Whitney and Executive Director, Josh Davis

The School Department Failed to Check Vendors for Suspension and Debarment Before Contracting Name of Contact Person: Michael Perrone, Director of Business & Finance Corrective Action Plan: The District will apply procedures, and or processes, to document all contracts with vendors that exceed $25,000 to include verification that the vendor is not subject to suspension/debarment prior to contracting. It is important to note, that on every Middleborough Public School purchase order contains the language “The offerer certifies that they and any principals are not presently debarred, suspended, proposed for debarment,or declare ineligible for the award of contracts by any federal agency” The District believed that a vendor honoring our purchase order (Contract) was in essence certifying that they were compliant with the language on our purchase order. Proposed Completion Date: The District will immediately make the necessary changes to comply with the aforementioned finding. It would be helpful if your team would supply the District with examples from other municipalities with acceptable practices.