Corrective Action Plans

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following: --One instance where the Cooperative did complete price comparisons; however, the memo documenting the procurement did not reference the price comparison. The procurement file did not obtain all required components of the procurement process including rationale for selecting the vendor or the procurement method used. --One instance where the Cooperative did not follow the procurement process as detailed in the procurement policy and no documentation was retained to support the rationale for selection of vendor. Corrective Action Plan: The Cooperative has taken steps to remedy the findings of the 2025 single audit: --Management reviewed procurement policies with department heads that are responsible for contractor and material procurement for grants. --Accounting staff will now review all grant expenditures at least monthly to catch new vendors in a more timely manner and assure that appropriate procurement policy has been adhered to prior to contractor starts work or material is used on projects. Responsible Individuals: Jeremy Richert, Chief Executive Officer and Kelly Gibbs, Chief Financial Officer Anticipated Completion Date: July 2026

The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide training to management staff on the procurement policies. Responsible Individual: Chief Financial Officer – Scott Korba Estimated Completion Date: October 2026-December 2026

2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Organization. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Organization review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Organization has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Board of Directors before the end of fiscal year 2026. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

Onvida Health Management will revise/update existing procurement and/or grant policies to incorporate all Uniform Guidance requirements related to micro-purchases, small purchases, competitive proposals, and documentation of cost or price analysis. Procedures for verifying suspension and debarment status will also be formally addressed in these policies. Responsible Official: Dana Alexander, Controller Completion Date: Any outstanding items not already completed that are listed in the corrective action plan, will be completed by an estimation date of October 1, 2026.

Finding 2025-003 Federal Agency Name: United States Department of Health and Human Services Program Name: Congressional Directives FFAL #93.493 Finding Summary: Testing of the federal program identified the following: 􀁸 The Hospital’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. 􀁸 Instances where the Hospital did not follow the procurement process, and/or retain documentation for reasoning of selection of vendor. Corrective Action Plan: For Finding 2025-003, the Hospital has updated and approved its Federal Procurement Policy and Procedure to incorporate all required elements of Uniform Guidance and strengthen compliance with federal grant requirements. In addition, the Hospital revised its Capital Request process to include formal procurement requirements, vendor selection documentation, and approval workflows. Effective immediately, no federal funds will be expended until the procurement process has been fully completed and documented in accordance with the revised policy. Management has implemented controls to ensure procurement records are maintained, including documentation supporting vendor selection and purchasing decisions. To support compliance and consistent application of the new requirements, education and training on the revised procurement and capital request processes will be provided to all managers on August 5, 2026. Hospital leadership will monitor adherence to these procedures through ongoing review and oversight to ensure compliance with federal regulations and prevent future occurrences of this finding. Responsible Individuals: Wesley Babers, Chief Executive Officer and Ashley Jaramillo, Chief Financial Officer Anticipated Completion Date: August 2026

We agree with the auditor's comments. A previously established procurement process titled School Fund Handbook was located, updated to reflect current purchasing process and policy per the Essex County Public Schools Policy Manual Section D, Fiscal Management on March 9, 2026. The Fund Handbook was distributed to administrative staff and a review and update recommended to incorporate all applicable requirements prescribed by 2 CFR §§ 200.318 through 200.326, including Federal procurement methods, competition requirements, documentation standards, and suspension and debarment requirements.

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE

Finding 2025-001 - Procurement: During the FY25 audit, it was noted that the Organization did not maintain a written procurement policy that included all the required elements. Corrective Actions Taken or Planned: Corrective action has been taken during FY26. The Organization updated the spending policy to reflect federal requirements and best practices and provided the document to the Audit & Finance Committees of the Board for review and comment. The updated spending policy is now in place. Completion date: 6/30/2026 Person responsible for corrective action: Nathan Kuder, Chief Financial Officer

The Partnership will develop and implement comprehensive written subrecipient monitoring and procurement policies aligned with Uniform Guidance. Procedures will include verification of suspension and debarment status (e.g., SAM.gov), incorporation of required compliance terms in subaward agreements, tracking of subrecipient funding by program, implementation of a risk-based monitoring framework, and documentation of monitoring activities including financial and programmatic reviews. Staff will be trained on these updated procedures, and compliance reviews will be centralized within the finance and administrative function.

FINDING 2025-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas 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, 2026

Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that updates procurement thresholds and outlined the standard for non-competitive procurement, requiring that sole-source determinations meet one of the specific allowable criteria under 2 CFR §200.320(c). 2. Rebuilding Together will further update the Procurement Policy to require that for noncompetitive procurements, management will prepare and retain contemporaneous written justification in the form of a sole-source justification memo demonstrating that the procurement meets one of the allowable criteria under 2 CFR §200.320(c), supported by appropriate documentation such as market research or evidence of exclusivity. The sole-source justification memo will be reviewed and approved by a manager senior to the staff member leading the procurement before the determination is finalized. 3. Rebuilding Together has developed standardized Micro-Purchase and Small-Purchase Procurement Memo templates that require documentation, at the time of procurement, of vendor selection rationale, price/cost reasonableness, competitive quotes obtained (as applicable), conflict-of-interest certification, and debarment/suspension verification. 4. Rebuilding Together is finalizing a Speaker Procurement SOP, which provides speaker-specific procurement guidance in accordance with 2 CFR 200. 5. Relevant staff (Development, Development Operations, Network Advancement, Communications, Grant Operations, and Finance) will receive training on the revised Procurement Policy and Speaker Procurement SOP. Anticipated Completion Date: The revised Procurement Policy became effective January 1, 2026. Additional edits to the Policy will be made implemented by September 15, 2026. Finalization of the Speaker Procurement SOP and related staff training are anticipated to be completed by December 31, 2026. Responsible Contact Person: Emma Weltzer, Director, Development Operations & Federal Grants

The Shaquille O'Neal Foundation acknowledges the observation regarding the documentation requirements under 2 CFR §200.318(a). While the Foundation did not have a formal written procurement policy in place during the audit period, it did implement procurement practices designed to comply with the Uniform Guidance requirements. Specifically, the Foundation maintained oversight of contractor performance in accordance with 2 CFR §200.318(b) by ensuring that all contractor agreements and applicable purchase orders incorporated the required federal contract provisions and procurement language. The Foundation monitored contractor performance to verify that work was completed in accordance with the terms, conditions, and specifications of each agreement. The Foundation recognizes that documenting these procurement procedures in a formal written policy is a separate requirement under 2 CFR §200.318(a). To address this deficiency, management has developed and adopted a written Procurement Policy that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). The policy formalizes the Foundation's procurement procedures, internal controls, competition requirements, contract oversight responsibilities, and documentation standards to ensure ongoing compliance with federal regulations. Management believes this corrective action fully addresses the audit finding and strengthens the Foundation's procurement governance for future federal awards.

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Description: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.027A- Grants to States; 84.173A- Preschool Grants H027 A230073 (Year: 2024), H027 A240073 (Year: 2025), H173A240081 (Year: 2025) $4,500 A review of expenditures charged to the Special Education 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: The School District has evaluated and improved internal control procedures by processing expenditures through the approved financial management system to ensure that required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Anthony Parrillo, Chief Financial Officer Telephone: 912-739-3544 Email: aparrillo@evanscountyschools.org

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (CSLFRF) – FEDERAL ALN 21.027 AND U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS – FEDERAL ALN 14.251 2025-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires City of Farmington, Minnesota (the City) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the Economic Development Initiative and CSLFRF federal programs. During our audit, we noted the City did not have sufficient controls in place within these programs to ensure compliance with federal requirements related to assuring that the City was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The City performed the required suspension and debarment verifications; however, documentation was not retained for two of the three vendors tested. To strengthen internal controls going forward, the City has implemented an updated procedure requiring staff to consistently retain documentation of suspension/debarment checks at the time of procurement for all federally funded contracts. This includes either (1) a SAM.gov screen print; (2) a copy of the contractor’s certification; or (3) a retained record of the method used. The Finance Director has reinforced this requirement with the responsible staff to ensure consistent and complete documentation going forward. Official Responsible – Kim Sommerland, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The City agrees documentation was not retained for two vendors. Plan to Monitor – The Finance Director will oversee compliance with the updated procedures and will conduct periodic spot checks to ensure documentation is consistently retained for all federally funded procurements.

2025-005: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edward Dickie, Business Manager.

2025-004: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Jim Serbin, CFO.

Contact Persons – Greg Welch, Finance Director& Jarek Wigness, City Engineer Corrective Action Plan – City officials have already implemented internal controls to ensure the proper oversight of federal programs according to the Uniform Grant Guidance Policy for Federal Revenue Sources. Completion Date – Ongoing

2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: 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. Responsible Party: Emma McQuillan, Chief Financial Officer Completion Date: 12/5/2024

Finding #2025-012 14.267 Continuum of Care GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management would like to clarify that verification of suspension and debarment status was performed through SAM.gov prior to the execution of subrecipient agreements. Historically, the process involved reviewing the entity’s suspension and debarment status directly through SAM.gov, and maintaining an electronic copy of the verification was not established as a standard documentation practice because the information was available for verification through SAM.gov. As changes have occurred to the availability and accessibility of historical SAM.gov records, management recognizes the importance of maintaining independent documentation of the verification performed. While the required verification was conducted, documentation evidencing the verification results was not consistently retained within the applicable procurement or subrecipient files. As a result, management was unable to provide sufficient supporting documentation during the audit to demonstrate completion of the required verification. Corrective Actions: Management will require retention of supporting documentation from SAM.gov verification, including the date of review and evidence of the verification results, within the applicable procurement or subrecipient file. The responsible program personnel will ensure that suspension and debarment verification is completed and documented prior to execution of applicable subrecipient agreements. The applicable procurement and subrecipient files will include SAM.gov verification documentation to support compliance with federal suspension and debarment requirements. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The updated procedures and documentation requirements have been implemented.

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

Management agrees with the finding and acknowledges that procurement approval documentation was not consistently retained during the audit period. Management notes that the finding primarily relates to documentation and retention of approval evidence, including reliance on verbal approvals and documentation gaps associated with system transitions. To address this finding, management has implemented corrective actions requiring documented, written approval for procurements prior to execution. The organization will use standardized approval workflows to ensure procurement approvals are properly evidenced, retained, and available for audit review. Management has also established a centralized repository for procurement records to improve accessibility, consistency, and document retention. In addition, management will enhance data backup and migration procedures to reduce the risk of documentation loss during future system transitions. These procedures will be incorporated into formal policies and standard operating procedures. Management will monitor compliance to ensure procurement documentation and approval controls are consistently followed across federally funded programs. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026. Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

FA 2025·001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) $6,267 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: To address this deficiency and prevent recurrence, the District will implement the following corrective actions: 1. Immediate Reinforcement of Quote Requirements Effective immediately, all School Nutrition and applicable district staff will be required to obtain and document price or rate quotations from a minimum of two qualified sources for all. 2. Pre-Approval and Verification Controls A pre-payment review process will be enforced requiring verification that: o Required quotes are documented o Procurement method aligns with federal thresholds o Vendor selection is properly justified o Payments will not be approved without complete documentation. 3. Staff Training and Accountability Mandatory training will be conducted for all School Nutrition Managers and staff involved in procurement to reinforce: o Federal procurement requirements o Documentation expectations o Internal control procedures Estimated Completion Date: July 31, 2026 Contact Person: Matoshia Grant, School Nutrition Director Telephone: 478-986-1390 Email: Matoshia.grant@jones.k12.ga.us Signature:Tonya Merritt Title: Cheir Financial Officer

Recommendation: We recommend that the Town continue to strengthen its formal procurement policies with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While to finance department has a procedure in place to review the Excluded Parties List system to ensure that the vendor is not debarred or suspended and to document such confirmation, we will further strengthen our procurement policies as follows: As part of the bid and vendor review, the Town Engineer will print off the Excluded Parties List at that time, initial and date it, and keep it with all bid documents. This will ensure that the list has been checked prior to any contract being executed. The finance office will continue their review when the vendor is set up in the financial management system. Name(s) of the contact person(s) responsible for corrective action: Cherie Trahan Planned completion date for corrective action plan: 06/30/2026

Procurement – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Review Contract and procurement policies and procedures. • Compare current procurement process and training to the policies and identify areas for correction and improvement. • Update Policies and procedures as needed. • Implement procedures to review vendors on a periodic basis. • Implement procedures and assign responsibility for checking off that procurement documentation exists and is in the vendor folder or designated area. • Retrain staff involved in procurement on updated procedures. • Monitor process and adjust as needed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: January 2027

Finding 2025-002 Procurement and Suspension and Debarment (Compliance) – 2020 Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In addition, the City did not retain adequate documentation for verification that vendors were not suspended or debarred parties. Corrective Action Plan Although the City was performing the review, the report from the SAM.gov website being maintained by the City to document said review did not provide evidence that there were no active exclusion records. Under the direction of the Finance Director working with the Senior Buyer / Analyst, this Procurement procedure and policy have been updated and distributed to the appropriate individuals. Adherence to this policy and procedure will be monitored by the Finance Director and the Internal Auditor.