Corrective Action Plans

March, 3, 2026 U.S. Department of Health and Human Services Dimock Community Foundation, Inc. and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc., 50 Washington Street, Westborough, MA 01581 Audit period: July 1, 2024 - June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD FINDING Material Instance of Non-Compliance: Finding 2025-001: Congressional Directives 2025-001 Assistance Listing Number 93.493 Community Project Funding/CDS Recommendation: We recommend that the Agency adhere to their procurement policy that aligns with the requirments set forth in 2 CFR 200.318-200.326 Action Taken: The procurement of construction services funded through this award was done in early 2023 and preceded Dimock's updated procurement policy which calls for competitive bidding. It also preceded changes in procurement leadership. Subsequent procurement for services have since been subject to competitive bidding by Dimock consistent with CFR 200.318-200.326. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call Luis Rivera, CFO at 617-442-8800. Sincerely, Luis Rivera, CFO

Management will follow procedures as outlined in its policies and procedures to ensure all stages of the process adequately conducted and documented.

Research and Development – Assistance Listing No. 10.205 Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. 10.512 Higher Education Institutional Aid – Assistance Listing No. 84.031 Recommendation: We recommend that the University review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is reviewing existing procurement policies and procedures and strengthening processes as necessary. Additionally, training is being provided to relevant personnel to ensure an understanding of proper procurement procedures. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: June 2026

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

1. Finding Summary: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. Testing of 50 procurement transactions identified that the College could not provide documentation that a suspension or debarment check had been performed via SAM.gov prior to the award for 13 contracts (exceeding the $25,000 threshold). Additionally, the contracts did not include a provision requiring the contractor to certify their eligibility. While the subsequent search of SAM.gov revealed that the vendors involved were not actually suspended or debarred, the College was in violation of federal compliance requirements. 2. Management’s Position – Management agrees with the finding. We are currently implementing a new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Staff training on federal procurement requirements will be required. 3. Corrective Action – Management will adhere to new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Management will consider whether certain contracts will require the contractor to certify their eligibility as part of the request for proposal or submission of a final contract. Staff training on federal procurement requirements will be required, with a target completion date prior to July 1, 2026. 4. Responsible Party – While the Office of Sponsored Research and Programs will be responsible for adherence to the policy and completing the checklist, the VP of Finance & Administration will monitor compliance of this process. Additionally, the VP of Finance & Administration will reinforce adherence of the new policy with personnel involved with any federal contracts, specifically ensuring that the executive cabinet members are aware as well as the Director of Sponsored Programs. 5. Implementation Timeline – Implementation effective July 1, 2026. 6. Status of Corrective Action (if related to prior year) – Corrective actions are in progress.

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non-compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

2025-003 – Procurement, Suspension and Debarment Cluster: Research and development Sponsoring Agency: Department of Energy, Department of Education, Department of Defense and National Aeronautics and Space Administration Award Name: A New Approach to Discerning Transport of Gases in MOFs, Citizen Diplomacy I, High Fidelity 2D Noise Resilient Superconducting, The Compton Spectrometer and Imager COSI, and solar Polarization and Directivity XRay Experiment PAD Award Number: DE-SC0025524, P021A240012, W911NF-22-1-0258, 80GSFC21C0059, and 80NSSC22M0098 Assistance Listing Title: Office of Science Financial Assistance Program, Overseas Programs - Group Projects Abroad, Basic Scientific Research, Science Assistance Listing Number: 81.049. 84.021, 12.431, 43.RD, and 43.001 Award Year: 2024-2025 Pass-through entity: N/A To address the Suspension and Debarment finding, the campus will update its Procurement Policy and Procedures documentation. Vendor onboarding procedures will be updated to include the automated Visual Compliance (VC) process. VC continuously monitors and reports on vendor status to the University. The process will include an escalation process to the Supply Chain Management (SCM) Chief Procurement Officer (CPO) or delegate. No suppliers will be approved while in Debarred or Suspended status. If a change to a supplier’s debarment or suspension status is reported, the supplier will be flagged as not open for ordering. This provides near real-time updates to the procurement system to prevent new requisitions or new purchase orders from being created. The CPO or delegate must approve any exceptions to allow ordering from a suspended or debarred supplier. The Federal Funds Checklist and the Source Selection and Price Reasonableness Form (SSSPRF) will be updated to reflect the increased federal micro purchase thresholds. The updates will also eliminate duplicate signature requirements and clarify that SSPRF completion is not required when a competitive bidding process takes place. The campus will also provide targeted training and competence development. SCM will continue to emphasize and conduct training for all buyers and change order preparers focusing on federal procurement compliance. These employees are the procurement staff that process high-value federally funded purchases. Training will specifically cover Suspension and Debarment, Source Selection, and Price Reasonableness. This training will also address situations where purchases change from non-federal funds to federal funds, requiring that all documentation be provided prior to the change. The order of operations that documentation must be provided prior to issuing a purchase order or making changes to a purchase order will be emphasized. Implementation will occur through updates to procedures and targeted training. Procurement Policy and Procedures documentation will be completed before June 30, 2026. Targeted training and competence development will be provided to procurement buyers who process orders above the micro-purchase threshold on federally funded purchases on behalf of the University. Targeted training is anticipated to be completed by August 31, 2026. For inquiries regarding this finding, please contact Mike Murphy at mike.murphy@berkeley.edu.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.555 AND 10.553) 2025-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 719, Prior Lake-Savage Area Schools (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Lisa Rider. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Lisa Rider, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

The District will strengthen controls to ensure all service contracts, including those charged to federal programs, are approved by the Board of Education and entered into the official minutes prior to execution and payment, in accordance with 2 C.F.R. § 200.318(a), state law, and District policy. Effective immediately, all service contracts will be submitted for Board approval before services begin. No contract will be executed and no purchase order will be issued without documented Board approval. Accounts payale will verify Board approval prior to processing payment. Procurement personnel and Federal program staff will receive training on Uniform Guidance procurement requirements, including suspension and debarment procedures. The Business Manager will perform reviews on Federal program expenditures to ensure ongoing compliance. The District believes these measures will correct the defiency and prevent recurrence.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.556) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future, including maintaining appropriate documentation. Official Responsible – Dawn Duevel, Business Services Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Dawn Duevel, Business Services Director, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

City Clerk will be putting the Grant award Policies and Procedures in place

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Ra Chhoth, Finance and Operations Executive Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plans to Monitor – The District’s Finance and Operations Executive Director, Ra Chhoth will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

FINDING 2025-005 – Procurement, Suspension, and Debarment (Partially Repeated from Prior Year Finding 2024-002) Audit Finding Description: For fourteen (14) out of fourteen (14) procurement transactions tested related to procurement and suspension and debarment compliance, the following was noted: 1. The Inner Voice, Inc. did not complete the appropriate procurement process. 2. The Inner Voice, Inc. did not maintain appropriate documentation to support the procurement method utilized. 3. The Inner Voice, Inc. did not maintain documentation evidencing that suspension and debarment searches were performed. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Corrective Action Plan: Management will review procurement policies and procedures to align with Uniform Guidance requirements. This will include documentation of procurement methods, adherence to competitive procurement standards, and verification of suspension and debarment status. Management will also provide training to concerned staff to ensure consistent implementation of the updated policies. Name of Contact Person Responsible for Corrective Action: Diana Mitchell, CPO / Khurram Navaid, CFO Planned Completion Date: March 01, 2026

Finding 2025-002 Significant deficiency in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: Management will revise the organization's procurement policy to amend the current dollar threshold, which was determined to be overly restrictive and inconsistent with operational needs and federal procurement standards under 2 CFR Part 200. The updated threshold will align with the Uniform Guidance requirements and provide clear guidance for competitive procurement processes. In addition, the organization will implement a standardized Vendor Justification Form. This form will be required for applicable purchases and will document the rationale for vendor selection, including the price analysis, sole source justification (if applicable), and confirmation that the procurement procedures were followed in accordance with federal requirements. These corrective actions are intended to strengthen internal controls over procurement, improve documentation consistency, and ensure compliance with 2 CFR 200 requirements. Anticipated completion date: August 31, 2026

FINDING 2025-004 Finding Subject: Special Education Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district will implement procedures for Procurement, Suspension and Debarment by following the listed steps: 1. Three quotes will be obtained for procurements between $50,000 to $150,000 by the district and contract be awarded. 2. Verification of Suspension and Debarment will be performed by a member of the business office in System for Award Management (SAM) or the district will collect the certification from the entity prior to entering into transactions with the selected entity. Anticipated Completion Date: 3/31/2026

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA)- Procurement and Suspension and Debarment Federal Agency: Department of Education Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Procurement and Suspension and Debarment compliance requirements. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: We will establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: June 30, 2026

The District will ensure that all federal procurement transactions are aligned with its procurement policy. As required under the District’s procurement policy, the District will retain all procurement related documents. Due to significant turnover in the Food Services Director and Chief Business Officer positions over the past few years, it was identified that certain district policies may not have been fully followed. Going forward, the District will ensure that procurement policies are properly followed.

Finding 2025-004 Internal Controls over Procurement Plan: The enhancement to the e-procurement system to ensure appropriate documentation is captured in the central procurement file was implemented in June 2025. Implementation Date: June 15, 2025 Contact: Aaron Rosenthal, Assistant Vice Chancellor Purchasing and Contract Management University of Illinois Chicago Aaronr1@uillinois.edu 312-996-8074 Bradley Henson, Director of Purchasing Purchasing and Contract Management University of Illinois Urbana-Champaign Bhenson4@uillinois.edu 217-300-2459

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

The Education Department is reviewing their procurement process and will implement controls to ensure procurement compliance is verified prior to contract execution and payment. Additionally, procurement training will be provided to administrators and staff involved in purchasing and grant management. Federal procurements will be monitored by the Business Manager and Superintendent.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200. Additionally, controls were not sufficient to ensure checks for suspension and debarment were documented before entering into covered transactions with third-parties. Planned Corrective Action: Management will continue to strengthen internal controls through the revised Procurement Policy, enhanced documentation requirements, and clarified approval procedures. A centralized tracking database has been implemented to document sanctions, suspension, and debarment checks, as well as other required verifications based on the nature of each purchase or service. These procedures are required prior to entering into covered transactions and are monitored through dual staff reviews. Management believes that ongoing monitoring and consistent enforcement of these procedures will ensure compliance and prevent recurrence. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026