Corrective Action Plans

CFDA 10.558 — Child and Adult Care Food Program Finding Type: Noncompliance / Significant Deficiency Corrective Action Plan The YMCA acknowledges the procurement finding related to the lack of formal agreements aiid procurement documentation for certain food vendors. Management has implemented the following corrective actions: 1. Develop and implement a formal procurement policy consistent with federal procurement requirements under 2 CFR 200.3 18-200.326. 2. Require written agreements or contracts for all vendors where annual purchases are reasonably expected to exceed the federal small purchase threshold. 3. Maintain procurement documentation, including vendor quotes, contracts, and bid documentation, in a centralized electronic file. 4. Provide annual training to staff responsible for purchasing and program oversight on federal procurement standards and documentation requirements. Responsible Party Gina Franklin and Karrie Stanford Expected Completion Date September 30, 2026

The Department of General Services (DGS) and Department of Parks and Recreation (DPR) management concur with the findings. To ensure full compliance with federal and district procurement requirements, DGS will implement a standardized procurement compliance checklist that mandates the retention of suspension and debarment verification documentation for all covered transactions. This will include confirmation of SAM.gov checks and other related tax compliance documents. Procurement staff will receive targeted refresher training on federal and district documentation and record-retention standards. Additionally, DGS will conduct internal reviews of procurement files to validate compliance and immediately address any deficiencies identified.

We concur with the finding and are implementing procedures to address all issues. Civil Air Patrol (CAP) experienced turnover in key positions within the General Counsel and Contracting offices, which resulted in a lapse in the consistent execution of procurement file review controls. As a result, certain required procurement reviews were not completed in accordance with CAP policy. CAP has since filled the vacant positions and initiated a comprehensive review of procurement files. This review includes the completion of the CAPF GCC-06 Procurement File Review Checklist, as required, and the retroactive reconciliation of procurement documentation to the extent practicable. In addition, CAP is strengthening internal controls by enhancing monitoring procedures to ensure procurement file completeness prior to closeout and providing targeted training to procurement and program staff on applicable federal and internal documentation requirements. CAP expects to complete the retrospective file review and fully implement these enhanced controls by 30 September 2026.

Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend that the District develop, approve, and implement written standards of conduct in compliance with 2 CFR §200.318(c)(1)–(2). The standards should address individual and District conflicts of interest, restrictions on gifts and gratuities, and disciplinary actions for violations, and should be communicated to all personnel involved in procurement activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will create a policy for conflict of interest requirements of Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025

FINDING 2025-004 The City does not have documented procurement policies and procedures in place as required by the Uniform Guidance. Furthermore, the City did not monitor contractor compliance with BABA provisions. Management’s Response The City will adopt documented procurement policies and procedures and monitor contractor compliance with BABA provisions in FY 2026.

The Institute's procurement policy will be updated to the passage of Act 202 1-296, now codified at Code ofAlabama 1975, Section 41-4-110, et seq.

Action taken in response to finding: The Commission is in the process of adopting an updated procurement and conflict of interest policy to comply with compliance requirements.

Going forward, Lighthouse Louisiana will ensure that its procurement policy reflects its commitment to purchases made in a manner that promotes full and open competition, supports price reasonableness, and maintains appropriate documentation based on the applicable procurement threshold. Management confirms that the Organization will apply a $10,000 micro-purchase threshold, require price or rate quotations from an adequate number of qualified sources for small purchases between $10,000 and $250,000, and require a formal competitive process for procurements exceeding $250,000, unless a properly documented exception applies. Lighthouse Louisiana did not actively retain all SAM.gov search results in vendor files for each vendor included in the procurement testing; however, if a SAM.gov verification was performed but not retained in the file, management will document the issue, perform and retain an updated verification, and strengthen internal controls to require retention of SAM.gov evidence before agreement execution or renewal. As part of its corrective action, Lighthouse Louisiana will enhance its procurement file review process to ensure that each grant-funded procurement contains, as applicable, the procurement method determination, supporting quotes or price comparisons, price reasonableness analysis, vendor selection rationale, required approvals, contract or agreement, and SAM.gov verification. Management will also reinforce staff training on procurement documentation requirements and will implement a standardized procurement checklist for grant-funded purchases. The Chief Financial Officer, Chief Operations Officer, and Project Director will be responsible for ensuring that any requested documentation is gathered and submitted to the auditors and that procurement file improvements are implemented prospectively.

Finding: Procurement, Suspension & Debarment: Congressional Grants - One procurement transaction for a building construction contract which covers 100% of the major program expenditures was tested. We noted that the expenditures of the major program were for valid allowable activities and costs however, we noted that the procurement, suspension and debarment requirements for a procurement transaction over the simplified acquisition threshold were not followed including, not obtaining competitive bids, missing cost/price analysis, and selecting the contractor primarily on qualifications but without a valid noncompetitive justification. Also, the suspension and debarment search was not conducted. valid. Management is in agreement with this finding. Below is the corrective action plan Views of Responsible Officials and Corrective Action Plan: Management acknowledges that procurement procedures did not fully comply with federal requirements for procurements exceeding the simplified acquisition threshold. Specifically, required elements such as competitive bidding, cost/price analysis, formal justification for noncompetitive procurement, and suspension and debarment verification were not consistently performed or documented. To address this matter, management will implement the following corrective actions: • Formalized Procurement Policy Update: Update and formalize procurement policies to align with federal grant requirements, including specific guidance for procurements exceeding the simplified acquisition threshold. • Competitive Procurement Procedures: Require documented competitive bidding or proposals for all applicable procurements unless a valid and documented sole-source or noncompetitive justification is approved in advance. • Cost/Price Analysis Requirement: Implement a standard requirement to perform and document cost or price analysis for all significant procurement transactions. • Suspension and Debarment Verification: Require documented verification (e.g., SAM.gov search) that all contractors are not suspended or debarred prior to contract award. • Enhanced Review and Oversight: Implement a secondary review control to ensure all procurement documentation is complete and compliant prior to contract execution and payment. • Training and Compliance Awareness: Provide training to relevant personnel on federal procurement requirements, including documentation standards and compliance expectations. Responsible Official Warren McLean Completion Date: The project was completed on December 30, 2025. Mortenson is the largest contractor in Minnesota, and the 5th largest contractor in the United States. They completed a very complex commercial kitchen, NEON Collective Kitchens, a 25,000 square foot facility, one of the 5 largest commercial kitchens in the country. Going forward, we will adhere to the corrective action plan that we outlined above.

CORRECTIVE ACTION PLAN Concerning Finding 2025-001 - Procurement Contact Person Responsible for Corrective Action: Darcy K. Labbe, Superintendent Corrective Action: The Eagle Lake Sewer District will take the following actions to address finding 2025-001. A procurement policy was drawn up and implemented on February 23, 2026. Anticipated Completion Date: A procurement policy was signed by the Board of Trustees and implemented on February 23, 2026.

The East Alabama Health Care Authority (the Authority) recognizes the importance of being sufficiently knowledgeable on federal grant requirements. Management acknowledges that while the Authority did complete procurement procedures in compliance with the grant requirements that it did not establish formal written policies and procedures addressing procurement methods, competition requirements, and documentations standards to be consistently applied to all procurement transactions under federal awards. To ensure compliance with federal grant awards moving forward, the Authority will document policies regarding unmet requirements described above. Management will ensure that procedures to meet these policies are implemented and that evidence of this implementation is recorded. Contact Person & Proposed Completion Date Contact person responsible for corrective action: Dennis Thrasher VP - Controller (334) 528-2104 Proposed date of completion: 9/30/2026

Finding 2025-002 – Significant Deficiency Award No.: 21.027 Federal Grantor: U.S. Department of Treasury, Passed-through the County of Butte, Pass-through Grantor’s Number X25534. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The Agency’s procurement policy does not adequately document procurement requirements under the Uniform Guidance or contract provisions under Appendix II to Part 200 of the Uniform Guidance. Criteria: Uniform Guidance, Section 200.318(a) indicates “the recipient or subrecipient must maintain and use documenting procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327”. Required contracting provisions are documented in Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Cause: The Agency’s procurement policy needs to be updated to document the requirements of the Uniform Guidance. Effect: The Agency’s procurement policy does not comply with the requirements of the Uniform Guidance, which could result in procurements that do not comply with the Uniform Guidance and the awarding agency disallowing the federal award and requesting the return of the award. Context: The Agency’s procurement policy complies with many requirements of the Uniform Guidance, but the policy does not comply with certain required provisions, including the thresholds for micro purchases, simplified acquisition threshold and full public procurements and the requirements for sole sourcing procurements under section 200.320. The procurements tested were found to comply with procurement requirements under Uniform Guidance even though the policy did not include all of the required provisions. Recommendation: The Agency should update its procurement policy to reference Uniform Guidance §§ 200.317 through 200.327 and should reference contracting provisions under Appendix II to Part 200 to be in compliance with Uniform Guidance prior to procurements being made under future federal awards. Views of Responsible Officials and Planned Corrective Actions: The procurement policy will be updated to include procurement guidance under Uniform Guidance §§ 200.317 through 200.327 and contracting provisions under Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Title of Responsible Party: Finance Manager Implementation Date: By September 22, 2026

Federal Single Audit Finding: 2025-001 Procurement, Suspension and Debarment – Significant Deficiency in Internal Control over Compliance Name and Contact Person: Janelle Friday, Tribal Administrator Corrective Action: Klawock Cooperative Association will create additional forms for both suspension and debarment checks and sole source transactions to ensure proper approval prior to purchasing from vendors whose expenditures would exceed the micro-purchase threshold. Proposed Completion Date: June 30, 2026

FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.

Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization plans to review its procurement and suspension and debarment policies and assess necessary changes to be in accordance with Uniform Guidance going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2026

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 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 the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us

2025-001 – Procurement/Suspension & Debarment Federal Program Information: Department of Education – Child Nutrition Cluster: CFDA – 10.553/10.555/10.556/10.559/10.579/10.582 Criteria: The following CFR(s) apply to this finding: 2 CFR 200.318 General procurement Standards and 2 CFR 200.214 Suspension and Debarment Condition: During audit procedures, it was identified that the Supervisory Union did not have internal controls in place to ensure that all appropriate procurement standards and procedures were followed. Cause: Unknown Effect: The Supervisory Union may not be consistently following all appropriate procurement standards and procedures. There were instances where the suspension and debarment verification were not performed. Identification of Questioned Costs: None identified. Context: Of the 8 procurement purchases tested, 6 were not verified for suspension or debarment in SAM.gov. Repeat Finding: This is a repeat finding. Recommendation: It is recommended that the Supervisory Union implements controls to ensure that it follows all appropriate procurement standards and procedures. We also recommend that the Supervisory Union review its procurement policy to ensure that it is updated and complete. Management Response: Management agrees with the recommendation and will implement controls to ensure we follow all appropriate procurement standards and procedures. In addition we also will review our procurement policy and ensure it is updated and complete. Anticipated completion date 7/1/2026

Procurement, Suspension, and Debarment Auditor Description of Criteria, Condition, and Effect: Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision In addition, the Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to Procurement (including bidding and a conflict of interest policy) (§200.318). For one of the two vendors tested, the YMCA was unable to provide documentation to support that competitive bidding was performed in accordance with the YMCA's policies and procedures. Although the YMCA has processes in place to cover these areas, we noted during review of procurement policies, that management has two procurement policies, one for general competitive bids and one for federal funds. We noted that while the federal funds procurements thresholds are in line to what is required by 2 CFR 200.318, the policy was not being followed consistently. As a result of this condition, one vendor was paid with federal funding for which appropriate procurement records were not maintained in accordance with federal procurement standards. The YMCA did not fully comply with the Uniform Guidance applicable to the above noted grant. Auditor Recommendation: We recommend that the YMCA review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. Corrective Action: Although we performed the proper procedures, the passage of time resulted in a misplacing of the supporting documentation. We relied upon legal counsel to retain the documentation. This was a unique and one-time award. In the future, we will take responsibility for the retention of the supporting documentation, Responsible Person: Phil Platz, CFO Anticipated Completion Date: 6/12/2026

Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal System for Award Management (SAM.gov) prior to contract execution. Anticipated Corrective Action Plan Completion Date: April 1, 2026 Contact Information: For additional information regarding these corrective actions, contact Stephen Bauer, CEO at 414.345.3240. Stephen Bauer CEO Guest House of Milwaukee

2025-008: Procurement Policy Condition: We noted that the Village does not have a documented procurement policy in place as required by 2 CFR 200.318. No instances of noncompliance were identified in the procurement transactions tested. Corrective Action Planned: A purchasing and procurement policy was created and discussed at the May 2026 finance committee meeting and approved by the board in May 2026. Name of the Contact Person Responsible for Corrective Action: finance department Anticipated Completion Date: May 2026

U.S. Department of Justice U.S. Department of Health and Human Services AUDIT FINDINGS: Finding Reference Number: 2025-001 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 the first part of fiscal 2025 did not specify a micro-purchase or small purchase threshold above which written quotes would be required, although this was addressed in January 2025. A formal written policy for ensuring vendors are not suspended or debarred was not included in the old policy and, although the new policy does include such language, no specific procedures were performed regarding the determination as to whether vendors were suspended or debarred. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new procurement procedure to ensure vendors are not suspended or debarred, was prepared and implemented effective in fiscal 2026. 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

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

VILLAGE OF BELLEVUE 201 N. Main St. Bellevue, MI 49021 269-763-9571 • Fax 269-763-9998 manager@bellevuemi.net • www.bellevuemi.net treasurer@bellevuemi.net 69 CORRECTIVE ACTION PLAN Certain matters were brought to our attention as a result of the audit process. These are described more fully in the Schedule of Findings and Questioned Costs. We evaluated the matters as noted below and have described our planned actions as a result. 2025-001 MATERIAL JOURNAL ENTRIES PROPOSED BY AUDITORS Views of Responsible Officials: Management agrees with the finding and will take appropriate steps to remedy noted finding. Corrective action plan response: The Village will take steps to ensure that material journal entries are not necessary at the time future audit analysis is performed. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026 2025-002 SEGREGATION OF DUTIES OVER KEY FINANCIAL PROCESSES Views of Responsible Officials: Management agrees with the finding and has taken appropriate action to remedy the bank reconciliation portion of the finding during fiscal year 2025. Corrective action plan response: The Village will take steps to actively seek ways to strengthen its internal control structure. This may include requiring as much independent review, reconciliation, and approval of journal entries and bank reconciliations by qualified members of management and documenting such review as part of the Village’s control procedures. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026 2025-003 BANK RECONCILIATIONS Views of Responsible Officials: Management agrees with the finding and will take appropriate steps to remedy noted finding. Corrective action plan response: The Village will take steps to ensure that bank reconciliations are documented as reviewed and reconciliating items are properly documented. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026

Federal Program: 93.045/93.053, Department of Health and Human Services, Aging Cluster Condition per Auditor:The County engaged a third party contractor to perform certain eligibility reassessments, including obtaining verification of medical necessity, when required. While the County had a process in place to properly identify when reassessment was required and to follow up with the contractor about the status of reassessments, controls did not ensure the third party contractor followed through on reassessments on a timely basis. Planned Corrective Action: The Department of Senior Services would like to clarify that the third party contractor is contracted through The Senior Alliance, the Area Agency on Aging for region 1 C and not Wayne County.Wayne County Senior Services will continue to monitor the third party vendor for timely assessments and reassessments through the existing controls which include:• Providing the third party contractor monthly lists of clients in need of assessment/reassessment• Generating monthly lists of outstanding reassessments (clients not reassessed from the monthly list)• Reminding clients of the requirement for 6 month reassessments• Obtaining updated information (phone numbers, emergency contacts, etc.) twice per year • Providing updated information to third party contractor• Documentation of communicated information regarding third party contractor’s performance to The Senior Alliance Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Joan Siavrakas

Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency will revise its procurement policy to fully align with the requirements of 2 CFR Parts 200.317-200.327, including procedures for all required procurement methods. This revision is being coordinated with the broader update to the Fiscal Policy and Procedures Manual currently underway to ensure consistency across all organizational policies. The CFO and CAO will work jointly to implement and monitor corrective actions in cross-functional areas, including timekeeping, payroll documentation, record retention, lease tracking, IT access controls, vendor onboarding, procurement documentation, and personnel training. This shared structure is intended to ensure that policy revisions are supported by clear workflows, staff training, documentation standards, and periodic compliance review. We note that no purchases during the audit period met the threshold requiring formal competitive bidding, and no questioned costs were identified. By September 30, 2026, the Agency will complete updates to procurement procedures.