Corrective Action Plans

The District of Columbia Public Library (DCPL) concurs with the auditor’s findings and recommendations. Management acknowledges the finding regarding the procurement that was awarded prior to receiving the federal funding and the procurement did not fully adhere to the standards outlined in 2 CFR Section 200. The Procurement was awarded under the District’s Municipal Regulations policies and procedures, we recognize that the 2 CFR Section 200 requirements are stricter. Effective June 12, 2025, DCPL will ensure that all Procurements comply with 2 CFR Section 200, including procurements awarded prior to receiving Federal funding. This includes: • Enhancing our internal review process and documentation to confirm the funding source and ensure Federal procurement regulations are followed. • Identify training for Procurement, Budget and Program Staff on Federal grant compliance and Procurements that fall under 2 CFR Section 200. Contact: Richard Reyes-Gavilan, Executive Director Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendors were not excluded from federal contracts due to debarment or suspension. Corrective Action Taken: Procurement findings: 1. Performance Foodservice had two (2) invoices dated May 2023 (FY23) paid in FY24. For FY23 the BOE had a contract with Performance. The invoices were for prior year. No purchases were made in FY24, only payment from FY23 purchases. BOE believes the purchasing policy was followed. 2. Sardilli Produce, had 3 PO’s entered in FY24. One PO was for $80,000 for yearly invoices. 58 invoices were charged to PO. Average invoice total was $1,289. The approved PO did not follow purchasing policy. Suspension and Debarment addressed in 2024-005. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures related to procurement in March of 2024. See FY23 Corrective Action Plan. However, the one procurement sample that was cited as not including “documentation of bidding, alternative price quotes or sole source documentation” contained a sole source justification that was developed before implementation of the FY23 Corrective Action Plan. The sole source justification was based on the specialized knowledge and specific expertise. Procurement samples for purchases or contracts after the implementation of the FY23 Corrective Action Plan, show compliance of adequate bidding, price quotes or sole source documentation consistent with 2 CFR 200. The NWIFC will continue to implement the FY23 Corrective Action Plan, by requiring NWIFC managers and their staff to be responsible for soliciting bids or developing sole source justifications for procurements and contracts consistent with 2 CFR 200. The Contract Specialist will ensure that bid solicitations and sole source justifications are properly documented and filed with each contract. Similarly, the audit noted that certain suspension and debarment samples selected, before the FY23 Corrective Action Plan was implemented in March 2024, lacked documentation of a suspension and debarment review prior to doing business with vendors. In response, the FY23 Corrective Action Plan, put into effect in March 2024, included measures to ensure that both new vendor and annual reviews are documented. The Accounts Payable department will continue to conduct suspension and debarment reviews for all new vendors before conducting business and perform annual reviews of all vendors, in line with the FY23 Corrective Action Plan. Anticipated completion date: Completed March 2024.

Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.

Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 29, 2026 A material weakness was issued related to internal control over suppliers under the UG audit. CFNI recognizes the need to comply with the procurement standards outlined in 2 CFR §§ 200.318-326, which require written policies addressing competition, conflicts of interest, procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurement), oversight, efforts to engage small and disadvantaged businesses, and procurement of recovered materials, among others. To address this deficiency, CFNI is committed to enhancing its documented procurement policies for procure-to-pay processes involving federal funds. The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists—periodic PeopleSoft program checks and an annual review by a third-party vendor—no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors. CFNI will develop and implement a robust supplier management policy, incorporating requirements for procurement, suspension, and debarment reviews. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements. The Problem: During testing the auditors noted that one instance of purchasing using WSDA funds was made without WSDA prior approval and proper documentation of suspension and debarment or WSDA prior approval. Established Standard: Organization must verify SAM registration and conduct suspension, and debarment checks prior to entering into any sub-agency agreement, contract, purchase, or equipment repair over $5,000. It is recommended that lead agency verifies, at least annually, that sub agencies and vendors are not suspended or debarred. Information about suspension and debarment checks is to be entered onto a spreadsheet of approved vendors. When the lead agency enters into a covered transaction with another agency or vendor, lead agency must verify that the entity with whom business is transacted is registered with SAM and is not excluded or disqualified. There are two methods for verification: A. Checking SAM.GOV exclusions (this method requires saving a copy of the verification search) B. Collecting a signed certification from the vendor. Actions to be taken: • Updated training of TCFB staff on the Policy/Procedures for procurements using WSDA funding. • Create step-by-step instructions for purchases using WSDA funding. • Effective October 1, 2024 WSDA’s threshold for preapprovals changed to $10,000. We will update our purchasing policy to reflect this change. Action Assignments: • Instruction checklist will be created by lead purchaser. • Lead purchaser will ensure that any purchases follow the Policy/Procedures for procurement. • Lead purchaser will be responsible for documenting SAM registration, Suspension and Debarment check, and WSDA pre-approvals. The documentation will consist of a copy of the exclusions page on SAM.GOV, as well as a spreadsheet of approved vendors with a date of last check. Timeline: • Instruction checklist for purchases using WSDA funds will be created by July 1st, 2025. • A spreadsheet has already been created to capture the information concerning Suspension and Debarment checks. A separate folder contains copies of each entities exclusion page from SAM.GOV. Verify Implementation: • In July 2025 Lead Purchaser will submit to the Executive Director: A. A copy of step-by-step instruction checklist. B. A copy of the spreadsheet with Suspension and Debarment checks C. Copies of exclusion pages from SAM.GOV Finance Dept. will verify invoice have received WSDA prior Approvals

2024-03: Lack of Procurement Policy Contact Person Heather Ferebee Corrective Action Plan A procurement policy will be developed and approved by the City Council. Completion Date 2025

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Moving forward, the district will perform a cost/price analysis for procurement in excess of $250,000.

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process The district has also since enrolled with Bonefish, a partner of OASBO and Ohio Schools Council (OSC) to satisfy all requirements of securing vendors/entities using the Federal government’s System for Award Management (SAM). This will create the proper internal controls that were lacking.

Corrective Action Plan Actions Planned – The City will hold pre-meetings with grant administrators to ensure all federal compliance requirements are met including verifying suspension and debarment. Official Responsible – Amy Sevig, Deputy Finance Manager Planned Completion Date – December 31, 2025 Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – Janet Burns, Grant Coordinator Accountant, will oversee the process to ensure pre-meetings are set up with grant administrators and the City is in compliance with all federal grant requirements.

Finding: The Foundation is responsible for implementing policies, including internal controls, that are designed to provide reasonable assurance regarding the achievement of the following objectives: effectiveness and efficiency of operations, reliability of reporting for internal and external use; and compliance with applicable laws and regulations. During the audit, it was identified that the federal procurement and other policies surrounding federal funds, as required under the Uniform Guidance (2 CFR Part 200), were not fully implemented until the latter part of the year. Consequently, certain procedures conducted prior to the implementation of the new policies did not incorporate all required federal standards. Corrective Action Taken: Management, under the leadership of the Chief Executive Officer, Josh Goldberg, has developed and fully implemented a comprehensive procurement policy compliant with federal regulations under the Uniform Guidance (2 CFR Part 200) starting October 2024. This policy ensures adherence to all required federal standards, including competitive bidding, vendor selection, conflict of interest, and documentation requirements. Staff have been thoroughly trained on the new procedures to ensure consistent application across the organization. Internal monitoring controls are in place to ensure ongoing compliance for all federally funded procurements. Management also maintains active communication with awarding agencies to ensure a clear understanding and proper implementation of all compliance requirements related to federal funds. Completion Date: January 1, 2025

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained. Corrective Actions Taken or Planned MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions: Policy and Procedure Update As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file. Procurement Checklist Enhancement Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented. Training Implementation All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications. Ongoing Monitoring A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained. Contact Person Responsible Tariq Bahich Senior Director Finance Anticipated Completion Date Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.

2024-001 Procurement Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Congressionally Directed Spending Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable In accordance with 2 CFR 200.318 the System must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. For two of two of the auditors’ selections sufficient documentation was not retained from the time of procurement during fiscal year 2023 to demonstrate sole source justification or the competitive bidding process for these samples. For one mammography technology asset, documentation of sole source vendor justification was not documented and retained by the System following Policy HA-50-42, Capital Equipment Requests. For the second selection, while competitive bids were obtained, management did not adequately retain documentation to support the vendor ultimately selected for the selected hardware component and the other bids obtained. Management has reviewed the Capital Equipment Request policy and the related capital request process and will reinforce the need to adhere to existing policies and the importance of retaining appropriate documentation during fiscal year 2025. Primary responsibility of implementing the Corrective Action Plan for this finding rests with Brian Huggins, Senior Vice President of Finance, Corporate Controller, (508) 334-0252.

U.S. Department of the Treasury AUDIT FINDINGS: Finding Reference Number: 2024-001 Description of Finding: Family Centered Services of CT, Inc. had not updated its procurement policy to conform to requirements in accordance with the Uniform Guidance. The policy in effect during fiscal 2024 did not specify a micro-purchase or small purchase threshold above which written quotes would be required. Additionally, a written policy for ensuring vendors are not suspended or debarred was not included in the existing policy and therefore this process was not being executed in a consistent manner. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new Uniform Guidance-compliant procurement policy, including a process to ensure vendors are not debarred, was prepared and implemented in January 2025. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed, Name of Contact Person: Jacquelyn Farrell, LCSW Executive Director 203-624-2600x204 jfarrell@familyct.org Projected Completion Date: Immediately

Management agrees with the finding. The City will implement procedures to ensure all purchases over $15,000 are formally approved by the City Council and are documented in the minutes.

May 27, 2025 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Re: Corrective Action Plan Regarding Section III: Schedule of Findings and Questioned Costs for the Fiscal Year Ended September 30, 2024, in Reference to 2024-001 Procurement It was identified in the findings of 2024-001 Procurement (repeat comment) that LCCMH had not followed proper procurement requirements and procedures regarding the agreement in reference to ALN 93.969 Certified Community Behavioral Health Clinics (CCBHC) expansion Grants. LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Thank you, Brooke Sankiewicz Chief Executive Officer Lapeer County Community Mental Health (810) 667-0500 bsankiewicz lapeercmh.org

Finding 2024-004 Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Lincoln’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management is working with our current auditors to update the Town’s procurement policies to be in compliance with Uniform Guidance. Name of Contact Person John Cimino, Finance Director Projected Completion Date 6/30/2026

The American Immunization Registry Association (AIRA) respectfully submits the following corrective action plan for the year ending September 30, 2024. Independent public accounting firm: HAN GROUP, LLC, Washington, DC Audit period: Year ending September 30, 2024 The finding from the year ending September 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2024-001 – Procurement, Suspension and Debarment. Audit Recommendation – Strengthen internal controls over procurement documentation by: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. Management Response – AIRA acknowledges the finding and will implement the following: 1. Procurement Checklist: A standardized procurement checklist will be developed and required for all federally funded procurements. This checklist will help ensure consistent documentation practices and that all necessary procurement steps and compliance elements are completed and retained. Documentation of the completed checklist will be retained in the procurement file. 2. Vendor Eligibility Verification: A formal review process will be established to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. Documentation of the eligibility check will be retained in the procurement file. 3. Staff Training: Targeted training sessions will be conducted on a recurring basis for all staff involved in the procurement process. These trainings will reinforce federal compliance requirements, including proper documentation practices and suspension/debarment verification. Training completion will be tracked and documented. Implementation Timeline – As of March 18, 2025, AIRA has implemented a verification of vendor eligibility process using SAM.gov. The procurement checklist will be developed and implemented by April 30, 2025, and regular trainings will commence by May 31, 2025. We are committed to ensuring full compliance with federal procurement requirements. Please contact the Business and Operations Director at 202-552-0208 with any questions.

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200 and management's internal policies and procedures related to procurement, suspension, and debarment. Planned Corrective Action: Management agrees with the improvement of documentation of procurement, suspension, and debarment. As noted below, purchasing policies are being followed, but were not always formally documented. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses. The findings noted three procurement contracts that were more than $50,000 that did not properly document the rationale for selection and/or sole procurement. The first contract was a single source provider for the replacement of thermostats. Other heating and air conditioning vendors would not handle the replacement of the thermostats as it was not their equipment. There was also a preventative maintenance agreement with the vendor: Phoenix Heating and Air. We will document the use of a single source contractor as allowed in our purchasing policies. We did follow the other control procedures regarding contract approvals, obtaining Certificates of Insurance and verifying completion of the work. The second contract was related to our website and marketing company: Brand Vibe. We did an open bid process, two years earlier, and renewed the contract without a formal bid process. As mentioned above, we did follow the proper approval process and verified the work was completed. The total of this contract for FY 2024 was $74,665, however only $3,600 was charged against the federal grant. Going forward, we will document the rationale for renewing the contract. The third contract was for a bi-lingual APN, with a Psych. Certificate, who was a former employee. She wanted to work part-time, and we switched her to a 1099 employee. With her experience and work record, we allowed her to transition to a part-time contractor. Our experience finding bi-lingual providers has been difficult, and the agency costs are almost double the cost paid for this contractor. The amount charged to the Trauma-Informed Centers of Care was $47,769. In the future, we will formally document the selection and use of this contractor. As noted, we did have a formal contract. and all providers are approved by the Board. Management will make necessary revisions to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200. Specifically, management will ensure the history of procurement - whether obtained through quotes, formal competitive bids, or through non-competitive means – is documented, including evidence that a cost-price analysis was performed for all purchases in excess of the simplified acquisition threshold. Additionally, before entering a covered transaction with third parties, management will have a form completed by the outside parties stating they are not suspended or debarred from engaging in federal activity before entering a covered transaction. This form will be retained, and we will check and document Sam.gov, excluded parties listing. Contact person responsible for corrective action: Karen L. Williams, Chief Financial Officer Anticipated Completion Date: 06/30/2025

Description of Finding The Town’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow their procedures as it relates to the contracts under the procurements applicable to the Town's major programs. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Town will develop a conforming procurement policy including all essential elements. Name of Contact Person Richard Monico, Director of Administration/Procurement Projected Completion Date June 30, 2025

Finding Summary: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids were not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Responsible Individuals: Andre Stringfellow, Chief Financial Officer Corrective Action Plan: Procedures will be developed and staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation. Anticipated Completion Date: August 2025

Corrective Action Plan for Annual Audit 2024 Finding One: 2024-001 Procurement, Suspension and Debarment Auditor’s Recommendations: Tacoma-Pierce County Chamber of Commerce should conduct research and keep records for procurements not secured using a competitive process. Corrective Action: TPCC Staff will continue to use a competitive procurement process for vendors when possible, per TPCC procurement policy. CEO, Andrea Reay, will amend the current procurement policy to include a process for when competitive procurement is not possible due to unique needs/benefits. This will include a process documenting research conducted that demonstrates the unique benefits to the program/participants for any vendor that is not secured using a competitive process. Documentation includes dates discussed, names of individuals involved in the discussion and decisions made. The debarment check with sam.gov will be included in the documentation packet. Timing of remediation completion: CEO, Andrea Reay, will complete by May 31, 2025.

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization document and maintain evidence of:  its completion of the required steps of its procurement policy for applicable transactions, and  suspension and debarment checks and procedures the Organization performs over vendors.Documentation and evidence of these procedures should be maintained to help show that the Organization in compliance with requirements specified in the Uniform Guidance. Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. Regarding suspension and debarment, CLS agrees on improving the documentation to comply and demonstrate compliance with this requirement, though CLS disagrees with the characterization of material weakness. Regarding the two procurement transactions, CLS disagrees strongly that these transactions were procurements subject to the CLS accounting manual procurement section. CLS provided documentation to the auditors demonstrating that these were not procurements but were, in fact, required by existing leases. In one instance, our Denver landlord required us to pay a “catch-up” payment for operating expenses it had underbilled us previously; this cannot conceivably have been a procurement as we did not have discretion not to pay it and it was required by an existing lease. The second instance was a payment related to the expansion of leased office space in Colorado Springs; that also was not a procurement as there was no alternative but to pay the existing landlord for increased space, and it could not conceivably have been conducive to third-party bidding etc. We understand that the auditors may prefer to have a sole source letter in these instances, but we disagree with any finding that this is required by our accounting manual and the auditors have pointed to no specific language in the accounting manual for this requirement. Action Taken in Response to Finding: The Organization will maintain evidence of the performance of its suspension and debarment checks and procedures performed. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026 If the Legal Services Corporation has questions regarding this schedule, please call Silvia Zelaya at 303-449-7575 or szelaya@colegalserv.org.

Action taken: Management has updated the process to verify that contractors are not suspended or debarred from receiving federal funds. While management was previously reviewing and confirming contractor eligibility, this confirmation was not consistently documented in the contractor records. Effective immediately, management has implemented a new step requiring the inclusion of a physical screenshot from SAM.gov in the contractor records. This adjustment ensures proper documentation and alignment with compliance requirements. Person responsible: ShaQuina Davis, Chief Operating Officer Date completed: February 10, 2025