Corrective Action Plans

The College will implement a written internal control policy on procurement procedures that conforms with 2 CFR sections 200.212 and 200.318 outlining that non‐Federal entities must maintain written procedures that align with federal standards, detail conflict‐of‐interest rules, and reflect applicable state or local laws.

Management will develop, formally approve, and implement written procurement procedures that comply with the Uniform Guidance procurement standards in 2 CFR §§ 200.317 through 200.327 and will be approved by the Board of Directors.

Regarding Finding 2025-001, pertaining to procurement, the Pennsylvania Broadband Development Authority has determined that the vendor in question was a project manager and did not provide general contracting services. As such, the rules regarding procurement were inapplicable. Please see the attached email from the Pennsylvania Broadband Development Authority. Related to any corrective action regarding this finding, pertaining to any future federal monies, Church of the New Covenant commits to using documented procurement policies which conform to the procurement standards in 2 CFR 200.317 through 200.327. Church of the New Covenant will in the future maintain records which sufficiently detail the history of procurement, including the rationale for procurement method, selection of contract type, contractor selection or rejection, and the basis for contract price. In the future, a staff person will be assigned the responsibility for the implementation of supervisory review procedures, for the review and updating of the procurement policy and procedures, and for the development of a standardized procurement file checklist.

Finding number: 2026-004 - Absence of Written Standards of Conduct Condition: The Organization had not adopted written standards of conduct addressing conflicts of interest and employee conduct requirements applicable to federal awards. Views of responsible official: Management agrees with the finding. The Organization will develop and adopt written standards of conduct addressing conflicts of interest and other ethical requirements applicable to federal awards and will communicate those standards to employees and Board members. Expected Completion date: November 30, 2026

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. One contract tested did not contain all applicable Uniform Guidance contract provisions. In one instance involving contracts exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Corrective Action Plan: KCEC will update its procurement procedures to incorporate applicable Uniform Guidance requirements. Debarment checks will be completed and documented for all vendors prior to contract execution while also ensuring that contracts contain attestation that the vendor affirms they are not disbarred. Contracts will be reviewed to ensure all required federal provisions are included. KCEC's Grant and Compliance accountant will strengthen its contract review process to ensure federal guidelines and language is present and included in contract verbiage by actively participating in contract negotiations between the vendor and KCEC. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

The Commissioner’s office will consult with legal counsel to update polices to meet requirements of 2 CFR 200.

FINDING 2025-018 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Vendor Setup & Conflict Verification: Standardized new vendor onboarding under the Purchasing Director. Requires W-9s, registration forms, annual SAM.gov suspension/debarment checks, state business registration checks, and local property tax searches to rule out employee/board conflicts of interest. Multi-Phase Procurement Overhaul: • Phase 1 (2025–2026): Established board-approval workflows for all contracts, quotes, and invoices. • Phase 2 (2025–2027): Enforced proper quote, bid, and special purchasing compliance. • Phase 3 (2026–2027): Updating board policies and internal controls to enforce federal uniform purchasing guidelines. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

FINDING 2025-013 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Enforced updated Internal Controls Manual purchasing thresholds and pre-approval workflows. Executing a multi-step resolution: board approval workflows established in 2025–2026, proper procurement/bidding compliance expanded through 2026–2027, and updating board policy to enforce uniform federal guidelines in 2026–2027. Anticipated Completion Date: June 30, 2027

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

Finding 2025-002 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2025 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding Summary: Corrective Action Plan: Responsible Individuals: 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 200.327. The Cooperative will update its written policy to include the requirements of 2 CFR sections 200.318 through 200.327. Denne’ Smith, Chief Financial Officer Anticipated Completion Date: December 31, 2026

Management concurs with the finding and recognizes the importance of maintaining consistent documentation supporting compliance with federal procurement, suspension, and debarment requirements. While WRTP|BIG STEP has procedures in place intended to ensure that it is in compliance with procurement requirements for federally funded activities, management acknowledges that documentation supporting those procedures was not maintained in a manner sufficient to satisfy audit requirements. During 2026, Management will establish standardized compliance checklists and procedures to ensure procurement requirements are being met. The planned hiring of a Finance Director will further strengthen oversight and accountability related to federal grant compliance and documentation requirements. The Finance Director will be responsible for overseeing grant financial management, federal and state grant compliance, implementation of internal controls, maintenance of supporting grant documentation, development and monitoring of compliance procedures, audit coordination, and ongoing verification that required documentation is maintained in accordance with federal regulations and Uniform Guidance requirements. Management believes these enhancements will strengthen internal controls over federal grant compliance and ensure adequate support is maintained for future audits.

Reference: 2025-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus, Mayor; Adam Gitter, Interim City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2026

The National Preservation Institute acknowledges the finding related to procurement documentation. While the National Preservation Institute believes its procurement activities were conducted in a manner consistent with Federal requirements, certain documentation necessary to demonstrate compliance was not retained in a manner that readily supported the procurement decisions. Management has reviewed the circumstances surrounding the finding and has reinforced expectations regarding procurement documentation, record retention, and compliance with Federal procurement requirements. Going forward, procurement files associated with federally funded activities will be reviewed to ensure that all required supporting documentation is generated and retained, including documentation supporting the basis for contractor selection, cost or price analyses, procurement method, and any other records required by Uniform Guidance. In addition, the National Preservation Institute will formally adopt a procurement policy designed to align with the procurement standards contained in Uniform Guidance, including requirements related to competition, conflict of interest, documentation, contractor selection, and procurement record retention. Management believes that the combination of a formal procurement policy and enhanced review procedures will strengthen compliance with Federal procurement requirements and ensure that procurement files contain sufficient documentation to support future monitoring, audit, and reporting requests.

Finding Number: 2025-004 Finding Title: Procurement Program: 16.710 Public Safety Partnership and Community Policing Grants Name of Contact Person Responsible for Corrective Action: Daniel Palmer, Deputy Director, Emergency Communications Corrective Action Planned: Upon review, we determined that program staff did not confirm with Purchasing and Contracting at the county that the contract was acceptable under our procurement policies which would have caught the error. Three generators were purchased under this contract, and the total cost was significantly below the expected and budgeted amount. To prevent this issue from occurring in the future, Ramsey County is implementing the following corrective action: • If the COPS Office determines that the $273,011 purchase of generators needs to be refunded, Ramsey County is prepared to submit a Grant Award Modification (GAM) requesting to use those funds to purchase additional needed radios for Emergency Communications and Corrections. • Enhanced training: We will provide regular training for departments to cover procurement policies and internal review processes at the department level. Anticipated Completion Date: December 31, 2026

Corrective Action Plan for the Calendar Year Ended December 31, 2025 In response to the finding from the Federal Single Audit for the fiscal year ended December 31, 2025. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2025-002- Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will continue to strengthen its processes and internal controls to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained. Christopher Caulfield, Assistant Vice President of Finance, will effectuate the corrective action plan, which will be completed by December 31, 2026. 973-754-2016

Management agrees with the finding. Management will spend additional time reviewing CFR section 200.318(i) for familarization. Assistance will again be requested to develop the additional proceudrement policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

FINDING 2025-003 Finding Subject: Drinking Water State Revolving Fund – Procurement Contact Person Responsible for Corrective Action: Beth Stocking, Clerk-Treasurer Contact Phone Number and Email Address: 574-223-2510 clerk@rochester.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City concurs with the finding. The City will adopt and use written procurement procedures for purchases made with federal award funds that incorporate applicable 2 CFR Part 200 requirements and the terms of each federal award. Before a purchase or contract is initiated, the City will identify whether federal funds are involved and determine the required procurement method based on the applicable threshold and type of procurement. The City will use required competitive procedures, public advertising, and formal procurement methods when applicable. Architectural and engineering professional services will follow applicable qualifications-based competitive proposal requirements. Any permitted noncompetitive procurement will include documented justification. Procurement files will retain solicitations, quotations or proposals, evaluations, approvals, contracts, and documentation supporting the method and selection. The Clerk-Treasurer will coordinate review of federal procurement requirements with the responsible department and professional advisors before federally funded contracts are executed, and personnel involved in federal awards will be instructed on the procedures. Anticipated Completion Date: December 31, 2026, with the procedures to be applied immediately to new procurements involving federal award funds.

FINDING 2025-004 Subject: Drinking Water State Revolving Fund - Internal Controls Federal Agency: Environmental Protection Agency Federal Program: Drinking Water State Revolving Fund (DWSRF) Assistance Listing Number: 66.468 Federal Award Numbers and Years (or Other Identifying Numbers): 2025 Pass-Through Entity: Indiana Financing Authority Compliance Requirement: Procurement Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the Town to ensure compliance with requirements related to the Drinking Water State Revolving Fund and Procurement compliance requirements as part of the Build America Buy America (BABA) requirement. Context: Crowe sampled two contracts that were subject to the procurement compliance requirements. Only one of the two contracts were subject to the Build America Buy America (BABA) requirements. Crowe noted that in that contract, management included contractual provisions addressing the American Iron and Steel requirements; however, the contract did not include provisions addressing the manufactured products and construction materials requirements applicable under BABA. As a result, the procurement control did not operate effectively to ensure that all applicable BABA requirements were incorporated into the respective contracts. Additionally, management was unable to provide sufficient supporting documentation demonstrating that construction materials used in the project were produced in the United States in accordance with applicable BABA requirements. Further, the documentation provided did not allow for a determination of the portion of total project costs attributable to construction materials as compared to iron and steel. Accordingly, Crowe was unable to determine whether the project complied with the applicable BABA requirements, resulting in a material weakness finding. Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Management will ensure their construction contracts include the BABA requirements, as applicable. Responsible Party and Timeline for Completion: The Town's Clerk-Treasurer will be responsible for implementing the corrective action plan, which will go into effect with future contracts that are entered into, as applicable.

FINDING 2025-003 Subject: Drinking Water State Revolving Fund - Internal Controls Federal Agency: Environmental Protection Agency Federal Program: Drinking Water State Revolving Fund (DWSRF) Assistance Listing Number: 66.468 Federal Award Numbers and Years (or Other Identifying Numbers): 2025 Pass-Through Entity: Indiana Financing Authority Compliance Requirement: Procurement Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the Town to ensure compliance with requirements related to the Drinking Water State Revolving Fund and Procurement compliance requirements as part of the small purchases procurement threshold. Context: One contract was subject to small purchase procurement testing for calendar year 2025. The Town disbursed $147,963 to DLZ, Inc. during 2025 for engineering services related to the new water treatment plant. Based on our testing, the Town did not obtain quotes or otherwise solicit proposals from other qualified engineering firms prior to procuring these services Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Town will enhance their internal controls process to ensure federal procurement guidelines are followed for future purchases based on the applicable thresholds. The procurement type will be documented and all related compliance requirements will be maintained. Responsible Party and Timeline for Completion: The Town's Clerk-Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: • The District has not formalized and adopted a written procurement policy. • In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. • In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for the vendor selection. Corrective Action Plan: The District will develop and formally adopt a written procurement policy addressing procurement activities involving federal awards and the applicable requirements of the Uniform Guidance. The District will establish procedures to document the procurement method utilized and the basis for vendor selection, verify and retain documentation that vendors subject to federal suspension and debarment requirements are not suspended or debarred from participation in federal programs, and ensure that federally funded contracts include applicable federal contract provisions required by 2 CFR Part 200. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: March 2027

In 2026, written procedures governing the allowability of costs charged to Federal awards and procurement activities involving Federal funds were developed, documented, and implemented. Responsibility for implementing and maintaining these procedures has been assigned to the Finance Department. The procedures address applicable Federal requirements for determining allowable costs and procurement activities and will be reviewed periodically and updated as necessary to maintain compliance with applicable Federal requirements.

Description of Corrective Action Plan: For any future projects funded with federal money, the City will ensure the federal procurement standards are followed. Anticipated Completion Date: Immediately, will be considered for any future procurements done with federal funds.

Finding Number: 2025-003 Finding Title: Procurement, Suspension, and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Tiffany Bailey – Fiscal Manager Corrective Action Planned: The planned corrective action is to improve and update the agency policy and procedures for procurement and implement a process with supporting documentation that ensures federal requirements are met. Anticipated Completion Date: December 31, 2026

Finding Number: 2025-002 Finding Title: Procurement Policy Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Tiffany Bailey – Fiscal Manager Corrective Action Planned: The planned corrective action is to improve and update the agency policy for procurement that ensures the required federal components are met. Anticipated Completion Date: December 31, 2026

See the Corrective action plant for chart/table