Corrective Action Plans

The Organization is in the process of revising its procurement and conflict of interest policies to ensure alignment with the requirements of 2 CFR §§ 200.318 through 200.326. During fiscal year 2026, the Organization will adopt updated written procedures and implement a formal internal control checklist to verify compliance with federal procurement standards across all grant-funded purchases. Staff responsible for procurement will receive training on the revised policies to ensure consistent application moving forward.

Corrective Action Plan: During Q4 2025, Shiloh’s general purchasing policy will be updated to consider the requirements included in 2 CFR 200.328 through 200.326. (Note: This update was originally to be implemented in Q4 2024 but was delayed due to unexpected turnover in the Business Department.)

Written procedures and conflict of interest policies in accordance with the Uniform Guidance will be established and implemented during the year ended June 30, 2026.

COVID-19 - Coronavirus State and Local Relief Funds (CSLRF)-Assistance Listing No. 21.027 Procurement Recommendation: The Town should review and enhance controls and procedures to ensure that it follows the established procurement policy for all goods and services charged to the program and should ensure that all departments are subject to applicable controls, policies and procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will implement procurement processes for goods or services exceeding $10,000 to ensure vendors are selected in a manner providing full and open competition where property or services are being acquired under a Federal award. Name(s) of the contact person(s) responsible for corrective action: Lewis George, Town Administrator Planned completion date for corrective action plan: 01/01/2026

Methodist recognizes the current gap between Supply Chain Services and the Research Institute related to retaining documents for procurement activities. Supply Chain Services will develop processes to retain written documentation for procurement activities in accordance with regulatory standards. As Methodist is in transition to a new ERP system in Quarter 1, 2026, Supply Chain Services will include strategies to address the needs in both the short term and long term.

2024-002 Finding Subject: COVID 19: Coronavirus State and Local Fiscal Recovery Funds - IFA Grant - White Ditch– Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources. Description of Corrective Action Plan: All purchases need to be made in accordance with the Sanitary District of Michigan City Purchasing Policy. All contracts will be supported by a written and signed contract document per Section 9.0 of the Sanitary District of Michigan City Purchasing Policy. Suspension and Debarment 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Description of Corrective Action Plan For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025

FINDING 2024-001 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources Description of Corrective Action Plan: All purchases need to be made in accordance with the City of Michigan City Purchasing Policy. Purchases made under the Special Purchase provision (I.C.5-22-10-1) will abide by section 7.4 of the Michigan City Purchasing Policy. This section describes the required record keeping. Suspension and Debarment Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.320 states in part: (a) "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . Description of Corrective Action Plan: For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025 INDIANA STATE

Federal Award Findings Finding 2024-003 U.S. Department of Treasury Passed through State of South Dakota Board of Water and Natural Resources Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The City does not have a formal documented procurement policy which includes written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts with federal funds . Responsible Individuals: Mike Steen, Mayor and Amanda Metzinger, Finance Officer Corrective Action Plan: Management plans to formally document and approve an official written procurement policy that follows all necessary state and federal laws, including the required procurement standards within 2 CFR sections 200.318 through 200.327. Anticipated Completion Date: 9/22/25

FINDING 2024-004 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately, which will include implementing a federal procurement policy. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Anticipated Completion Date: August 30, 2025

Program: Summer Food Service Program CFDA: 10.559 Finding Type: Noncompliance / Significant Deficiency Issue: Purchases from two food vendors exceeded the micro-purchase threshold without documented price comparisons or quotations. Management's Response: Response: Management acknowledges the importance of adhering to federal procurement standards, including the requirement for competitive pricing and documentation for purchases exceeding the micro-purchase threshold. Corrective Action Taken: Staff involved in procurement have been trained on 2 CFR 200.318-200.326 to ensure understanding of federal procurement requirements. A procurement forecast is now developed at the beginning of each grant cycle to identify vendors likely to exceed the micro-purchase threshold. . For all vendors expected to exceed $10,000 in purchases, the YMCA will obtain and retain at least three price comparisons or quotations. A procurement checklist and documentation log have been implemented to ensure compliance and audit readiness. Responsible Individuals: Karrie Stanford and Gina Franklin Completion Date: Plan has been implemented as of the date of audit submission.

District has been in discussion with our attorney and have already got a new ordinance written and put into effect as of June 1, 2025. CVDWSD currently has a procurement policy as a ordinance.

Action taken in response to finding: • LMC Staff will be re-trained on the process and importance of retaining documentation that SAM.gov was used to verify that a vendor was not suspended, debarred or otherwise excluded from participating in the transaction prior to contract. • LMC staff will review the OIG exclusions list prior to onboarding or signing contracts with vendors. • LMC staff will print and retain proof of each review for reporting purposes Name(s) of the contact person(s) responsible for corrective action: Melissa D’Onorio, CEO, and Donna Landy, CFO. Planned completion date for corrective action plan: 07/14/2025

The Town of Ramah is in the process of creating a Procurement Policy.

Retrained all staff on procurement policies – the approver misunderstood and thought that because this was a reimbursed cost that the higher level signature was not needed, so we have clarified that approval limits apply regardless of whether it is a reimbursable cost Establishing new, more automated procurement approval process that allows us to set approval levels for each user and will reduce potential for errant approvals Ensure all new management staff receive and acknowledge the procurement policy

Finding 2024-002: Federal Transit Cluster – Procurement and Suspension and Debarment (Noncompliance and Significant Deficiency in Internal Control) Condition: In some procurement files, TANK had missing documentation of procurement history, missing required contract clauses, lack of evidence of contractor responsibility determination and missing lobbying and Buy America certifications. Corrective Action: TANK implemented new procurement procedures and a revised checklist which outline and confirm all of the FTA-required clauses for any federal procurement. TANK documented and submitted procedures for obtaining signed lobbying and Buy America certifications in all procurements over $100,000/$150,000. TANK documented our procurement procedure which requires a responsibility determination to verify that contractors were not debarred or suspended from participating in federal awards by checking for System Award Management (SAM) certification. TANK included in the new procurement procedures an update of the record-keeping of procurement history to include elements such as rationale for the method of procurement; selection of contract type; reason for contractor selection or rejection; and basis for the contract price. Responsible Party: Lyndi Whiteker, Procurement Analyst Anticipated Completion Date: Complete and findings were closed between 7/19/2024-11/26/2024.

FINDING 2024-002 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas A. Dippel, CPA Contact Phone Number and Email Address: (812) 683-2211 / ct@huntingburg-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with the City’s attorney to revise its current policy to include federal regulations and procedures related to Procurement and Suspension and Debarment. Once revised, the City will follow its policy to ensure compliance with the compliance requirement. Anticipated Completion Date: September 30, 2025

Finding 2024-005 – Lack of Written Policies Required by the Uniform Grant Guidance Contact Person: Nicole Roberts, 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: December 31, 2026

Corrective Action: 1. Develop procurement procedures for procurement transactions under Federal awards or subawards, including verification that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. 2. Provide training to relevant staff on the new procedures for procurement transactions, including the verification of suspension and debarment for any subrecipient awards and the importance of compliance with federal regulations.

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Federal Financial Assistance Listing #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following • The Cooperative’s formally documented procurement policy was missing one required element as it relates to the methods of procurement. • 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 • One instance 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. • Two 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: The Cooperative has taken several steps to remedy the findings of the 2024 single audit: • In April 2025, the Board of Directors approved a revised procurement policy that includes the missing method of procurement. • Existing contracts have been amended to include required contract provision in accordance with Uniform Guidance. Any new contract will include those provisions. • All current contractors have been reviewed to ensure the vendors are not suspended or debarred. All searches have been printed and retained. Any new contractors will be reviewed prior to their selection as a vendor. • The reasoning for utilizing single-source vendors has been formally documented and signed off on by management. • All bid processes are now formally documented, including cost comparisons between vendors. Responsible Individuals: Jeremy Richert, CEO and Kelly Gibbs, CFO Anticipated Completion Date: July 2025

The College will retain all procurement documentation going forward..

Corrective action planned: Two new policies will be implemented; a board policy to cover board approvals for the bidding of large projects and an internal policy and procedure which spells out additional requirements, like requiring three written bids for large purchases. In addition, all members of the Board of Directors and senior leadership team will sign Conflict of Interest statements on an annual basis to confirm that they do not have any potential conflicts that could impact purchasing decisions. Anticipated completion date: July 31, 2025 Contact person responsible for corrective action: Steve Lindemann, Interim CFO

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Department of Homeland Security and Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: The Cooperative's procurement policy had not identified the dollar thresholds of procurement within the methods of procurement. In addition, one contract selected for testing was missing one of the required contract provisions. Corrective Action Plan: The Cooperative is working with our attorney to update the procurement policy to include the dollar thresholds of each method of procurement. We will update the procurement policy after acceptable changes are made. Responsible Individuals: Shelly Hove, CFO Anticipated Completion Date: September 2025

Identification Number: 2024-001 Finding: Procurement, Suspension and Debarment Corrective Actions Taken or Planned: The Armed Services YMCA (ASYMCA) acknowledges the control deficiency identified in the area of procurement policy and is actively addressing it to ensure full compliance with 2 CFR § 200.318 (formerly referenced as 2 CFR 300.218), which governs procurement standards for non-federal entities receiving federal awards. 1. Policy Development and Alignment with Federal Regulations ASYMCA Finance is currently compiling and formalizing procurement procedures in accordance with 2 CFR § 200.318. This initiative will result in a comprehensive, board-approved procurement policy that ensures compliance with federal requirements and strengthens internal controls. 2. Existing Policies and Controls ASYMCA already maintains consistent, documented, and approved policies in several key areas of procurement and financial management, including: • Authority of Responsibility: Delegation of authority for designating funds and obligating ASYMCA for purchases, including spending thresholds and approved personnel. • Procurement Standards: General procurement principles and internal controls. • Professional Services and Consulting Agreements • Purchase of Capital Items • Signature Authority • Legal Review • Unbudgeted Expenditures • Record Retention • Policy Enforcement and Consequences • Procedures for Invoicing, Payment Processing, and Reimbursements (Travel and Non-Travel) • Requesting New Vendors • Competition: Requirements for full and open competition in vendor selection.   3. Areas for Expansion and Integration To ensure full compliance with federal procurement standards, ASYMCA will expand its current policies to include the following areas: • Conflict of Interest: Clear guidelines to prevent personal or organizational conflicts in procurement decisions. • Methods of Procurement: Defined procedures for micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals. • Purchase/License of Technology or Software: Standards for evaluating and acquiring digital tools and platforms. • Indirect Cost: Clarification of treatment and allocation of indirect costs in procurement. • Methods of Procurement (as per federal thresholds) • Contracting with Small and Minority Businesses and Women’s Business Enterprises • Contract Cost and Price Analysis • Federal Awarding Agency Requirements 4. Implementation Timeline ASYMCA is committed to finalizing, approving, and implementing the updated procurement policy the end of the 2025 reporting period. This will include: • Internal review and legal vetting (if necessary) • Board and/or Audit Committee approval • Staff training and dissemination of the policy • Integration into operational procedures for all federally funded and non-federally funded projects Conclusion ASYMCA is committed to maintaining the highest standards of accountability, transparency, and regulatory compliance. The actions outlined above demonstrate a proactive and structured approach to addressing the control deficiency and ensuring that all procurement activities are conducted in accordance with applicable federal regulations. Anticipated completion date: December 31, 2025 Responsible Contact Person: Laura Tate-Smith, Chief Financial Officer

Finding Number: 2024-001 Recommendation: Create a procurement policy that meets the requirements detailed in 2 CFR 200.318– 200.327 Action Taken: AANA will implement a new Procurement Policy as it relates to purchases and grants supported by the MAST program. See document “MAST Procurement Policy” Responsible Contact Person for Planned Corrective Action: Dennis Siena Anticipated Completion Date: September 30, 2025

Corrective Action Planned: The USGA will enhance the procedures within its Policy for the Acquisition of Goods & Services relating to procurements utilizing Federal funding. In particular, the Policy will be amended so that adequate documentation is retained to ensure compliance with the requirements for the procurement methods described in 2 CFR §200.320. Further, the updated Policy will include additional requirements to ensure that applicable documentation of the USGA’s suspension and debarment verification procedures is retained and attached to any related purchase order in the USGA’s ERP system. At the time of the Policy’s approval by the USGA’s Executive Leadership team, the document will be shared with all employees and posted on our internal shared site where Finance related policies are stored and may be referred to. The USGA’s Finance/Accounting Department will be responsible for identifying grants to which the updated Policy applies and to assist with retaining the relevant documentation. The USGA’s Finance/Accounting Department will also develop a unique coding/project identifier to assist with ensuring that the request to purchase via a Purchase Order (PO) is visibly different than a generic PO when Federal funding is involved.