Corrective Action Plans

Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend that the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so it is clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Bill Holmgren Planned completion date for corrective action plan: June 30, 2026

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 16, 2022, to administer the federal grants to ensure that the Town would comply with allfederalprogram requirements. The Town was led to believe that they were in compliance with all federal program requirements. This is the second year of both federal grant programs, and the Town is just being made aware of the suspension and debarment requirement. It should be noted that all contractors and the consultant are not on the suspension and debarment lists.

All payments to contractors and vendors for the Water Sector Program are reviewed and approved by the outside consulting firm prior to payment. The outside consultant directs the Clerk as to the amount to pay and who to pay. The outside consultant acknowledged that they made the error in instructing the Town to make the payment. The State of Louisiana was contacted by the outside consultant to discuss the corrective action plan. The State advised the consultant to not make any corrections to the pay request that they would “bagout” the overpayment. Before the next pay request, the contractor returned the overpayment which was deposited into the Town’s Water Sector grant bank account.

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).

CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This policy, which includes a Conflict of Interest section, was updated to reflect a decrease of the micro-purchase threshold from $50,000 to $10,000, clarifies that the SAM.gov check for suspension and debarment will occur prior to contract execution with the contractor, and the SAM.gov check will be documented with the date it was conducted. The updated CIF Procurement Policies & Procedures will be approved by the Board of Directors.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Missy Schultheis Contact Phone Number and Email Address: 812-354-8478 mschultheis@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review and update the existing procurement policy to ensure it clearly outlines the procedures for different purchasing methods including the specific thresholds. We will establish a procedure requiring the retention of all documentation supporting procurement decisions. We will develop a process to verify that vendors/contractors are not suspended or debarred by any federal or state agency prior to entering into a "covered transaction" or contract. Anticipated Completion Date: This be implemented in the 2025-2026 school year and will continue for future years.

To ensure compliance with all procurement regulations and established procedures, the Executive Director of Operations, Alnita Miller, will ensure that procurement procedures are appropriately documented, reviewed and followed for all school food service department purchases; ensuring all inputs entered into the bid analysis summary are complete and accurate. These controls will be implemented forthwith.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend that management review the procurement, suspension and debarment requirements for federal programs as well as the organization's policies related to these requirements. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy review & update: Completed a comprehensive review of federal procurement, suspension and debarment requirements and revised the organization’s policies to align with those standards. Vendor assessment: Screened all active vendors against the SAM .gov exclusion list; documented results and removed or remediated any non-compliant relationships. Training & communication: Held mandatory training for procurement, finance and compliance teams on the updated policies and federal requirements. Ongoing monitoring: Established process to communicate exclusions to senior management to ensure continuous adherence. Name of the contact person responsible for corrective action: Christine Simiriglia, President & CEO Planned completion date for corrective action plan: June 30, 2026

Corrective Action Plan: The Loysville Village Municipal Authority disagrees with this finding. The Authority is bound by the procurement procedures contained in the Municipal Authorities Act (Pennsylvania law) and has signed agreements with USDA governing its procurement procedures. These documents are in writing and any additional policy for this purpose would either by conflicting or superfluous. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Secretary, Barry Enck, Treasurer

Procurement - Special Education Cluster (IDEA) (Significant Deficiency) Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. The Board of Education failed to solicit written quotations (in noncompliance with federal UG for procurements over $10,000) related to a contract paid under the grant. Under local policy, sealed bids should have been obtained for a competitive procurement over $25,000. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education will review its procurement processes to ensure they comply with local policies and federal guidance. Name of Contact Person Christian Strickland, BOE Chief Operating Officer Projected Completion Date June 30, 2025

MATERIAL WEAKNESSEs, 2025-001 - PROCUREMENT There is a material weakness identified in the audit that The District does not have the necessary internal controls over compliance and does not appear to have understanding or knowledge of the contract requirements for service contracts. Corrective Action: Central Office Staff and Staff responsible for Federal Grants and Programs will familiarize themselves with and implement the proper procedures and requirements for service contracts and procurement methods to ensure it meets the requirements in the District Policy and Federal Procurement requirements. Anticipated Completion Date: January 31, 2026

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Pass-Through Entity: State of Wyoming Office of State Land and Investment Board (OSLI) Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: We did not have a written procurement policy in place that aligned with all federal regulations. We also did not review vendors to ensure that they were not debarred, suspended, or otherwise excluded from participating in federal awards. Corrective Action Plan: We will review and update our procurement policy to align with all federal requirements, as well as revise our vendor policy to ensure vendors that are used for federal awards to ensure that they are not debarred, suspended, or otherwise excluded from participating in Federal awards. Responsible Individuals: Jim Cussins, CFO Anticipated Completion Date: March 31, 2026

Corrective Action Plan Contact Person(s): Janet Carbary, Deana Gilpin Management agrees with this finding and recognizes the need to strengthen internal controls over purchasing processes to ensure compliance with Uniform Guidance requirements (§200.317–§200.326; §200.213). To address the deficiency, the Organization will implement the following actions: 1. Update Purchasing Policies and Procedures o Purchasing policies will be revised to clearly incorporate Uniform Guidance requirements, including competitive bidding thresholds, procurement method selection, and documentation standards. o Policies will explicitly require verification of suspension and debarment status for all vendors receiving federal funds. 2. Implement Mandatory Suspension and Debarment Verification o Staff will be required to document verification through SAM.gov or other approved sources before awarding or renewing contracts funded by federal awards. o A verification will be maintained and reviewed by Finance leadership. 3. Enhance Procurement Documentation Controls o Leadership will ensure all federal purchases meet the requirement below before purchase approval. • Competitive purchasing requirements are met • Cost/price analyses are documented when required • Suspension/debarment verifications are completed and retained 4. Training for Finance Staff o Staff involved in purchasing, contract approval, and grant management will receive training on Uniform Guidance procurement rules and suspension/debarment requirements. 5. Periodic Internal Monitoring o Revenue accountant will monitor expenses related to federal programs monthly to ensure compliance. o Senior management will be notified if corrective steps are needed. Anticipated Completion Date: December 31, 2025 Responsible Officials: • Chief Financial Officer (CFO) • Accounting Manager • Director of Financial Planning

Suspension and Debarment Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management recognizes that even though none of the vendors utilized were suspended, debarred or otherwise excluded, the potential for violations increase if the verification is not done prior to engaging in transactions. For grant expenses with federal funding, LCHC management has implemented mandatory SAM.gov verification for all vendors prior to contract execution, with documentation retained in procurement files. LCHC has held meetings where applicable staff have been informed of compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025 If there are any questions regarding this plan, please call Jeffrey Nelson at 872-588-3033

The District Cafeteria Manager, Melanie Pardini, corrected this procedure for fiscal year 2025-26 and has the process in place going forward for each fiscal year.

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. Kayla Quick, Accounts Payable Clerk. 6/30/2026

Criteria: According to 2CFR 200.318(i) the recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The School did not maintain records for food and construction vendors that met the acquisition thresholds for the year. Cause: The School's procurement policies do not address the frequency of which vendors should be evaluated. In addition, the policies also do not address records retention. Potential Effect: The procurement may not have been proper under the grant requirements.Recommendation: We recommend that the School follow federal procurement guidelines for each of the different purchase thresholds for each vendor. We further recommend that the School retain any documentation created related to the procurement selection and vetting process. Action: As of the date of this exit conference, we will adopt the above recommendations, securing and retaining the appropriate documentation of vendor selection and retention.

We acknowledge the audit finding and agree that, for the two vendors identified, documentation of suspension and debarment verification was not completed or retained in accordance with proper internal controls for our federal programs. This was an oversight in our procurement documentation process and not an intentional omission. Neither vendor had any exclusions based on the SAM.gov database record. Since becoming aware of this issue, the organization is in the midst of implementing the following corrective actions to strengthen compliance with suspension and debarment requirements: (1) Revised Procurement Procedures- We will update our written procurement policies and procedures to explicitly require and document suspension and debarment checks prior to the execution of any contract using federal funds. This includes checking the federal SAM.gov database or obtaining a signed certification from the vendor, as permitted. (2) Standardized Documentation- We will create a standardized checklist that must be completed and filed in the procurement record for each vendor before payment of federal funds. This form documents the date, verification method, and staff member responsible. (3) Staff Training- All staff involved in procurement and accounts payable will complete training on federal procurement requirements, including suspension and debarment verification. This training will be repeated annually and upon onboarding of new staff. (4) Internal Control Review- A secondary review step has been added. Before any payment of federal funds is processed, our finance team will verify that the suspension and debarment check is on file. This dual review adds an additional layer of assurance.

OBI will update current purchasing and procurement policy to specifically address the acquisition of property or services using federal grant funds to ensure adherence to Federal procurement standards in 2 CFR Part 200 sections 200.317-200.327. Our policy will outline requirements regarding vendor selection and vendor qualification. It will address the simplified acquisition threshold, micro purchases threshold, and the formal procurement methods that must be adhered to when the value exceeds those thresholds. The policy will include when sealed bids, proposals/requests for proposals are required and when sole source procurement is appropriate and allowable. Whenever sole source procurement is used, the rationale will be documented and approved. Our policy will include language requiring that all vendors and contractors paid using federal funds be checked for federal suspension & debarment using Sam.gov. Vendors found on the exclusion list will not be paid using federal funds. The policy outlines requirements for written approvals and documentation of all procurements. Additionally, OBI has implemented procedures to ensure that at the point of receiving the Notice of Award, any federal money or grant awarded to OBI will be immediately communicated to the CFO, Controller, and the Senior Accountant. Person(s) Responsible: Senior Accountant with review and approvals from Controller and CFO Estimated Completion Date: January 31, 2026

We agree with auditor's comments, and the following actions have or will be taken to ensure the procurement of goods and services for the nutrition services department follows all applicable steps according to Title 2, Code of Federal Regulations (2 CFR) sections 200.317 -200.327; Title 7, Code of Federal Regulations (7 CFR), parts 210 and 220; and all applicable state and local rules: 1. During the school year 2024/2025, changes were made to staff to allow for additional oversight. A Procurement Specialist reporting directly to the Director of Purchasing was added to staff in lieu of a Buyer that had previously reported to the Director of Nutrition Services. This move allowed for an additional step to ensure proper procurement is happening. 2. All purchasing methods, including Micropurchase, Simplified Acquisition, and Formal, will be followed in accordance with all applicable regulations, in line with RUSD's written procurement procedures. 3. Any noncompetitive procurement will only occur if the conditions outlined in applicable regulations are met and sufficient evidence and documentation is received and retained, including participating in performing due diligence to ascertain whether a single source document is accurate from any given vendor. 4. In addition documented annual training will take place for all staff involved in the procurement process. This procedure includes a review and annual update of procurement procedures, if applicable, and an acknowledgement of the nutrition services code of conduct in regards to purchasing. Please reach out to us with any questions.

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village 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 Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026