Corrective Action Plans

The Town acknowledges that small purchase procedures were not followed in the transaction that occurred. Price reasonableness was not insured and bids were not obtained. The Mayor and Town Clerk shall improve procurement procedures and obtain a minimum of three bids on all projects that do not require public bidding or that are not on state contracts above the procedure threshold established by the Town. The Town will further update its written procurement policies and procedures to clearly define small purchase requirements, including quotation thresholds and documentation standards. Procurement staff will solicit and retain documentation of price or rate quotations from an adequate number of qualified sources for all small purchases. The staff will receive training under 2 CFR Part 200, including informal procurement methods and finally the Town will implement a supervisory review procurement file system to ensure compliance prior to payment, a checklist of sort to ensure proper document is secured.

The Town acknowledges the lack of written policy and procedures for expending federal funds and insuring vendors are not debarred, suspended, or ineligible to receive federal funds. The Town shall (1) Update its written procurement policies and procedures to require verification of vendor eligibility through SAM.gov prior to awarding any contract or issuing any purchase order funded with federal awards. (2) Require procurement staff to retain documentation of the suspension and debarment verification. (e.g., dated SAM.gov search results or vendor certifications). (3) Provide training to relevant personnel on federal procurement requirements including suspension and debarment compliance under 2 CFP Part 200.

Item: 2025-001 Assistance Listing Number: 93.185 Program: Immunization Research, Demonstration, Public Information and Education Training and Clinical Improvement Projects Federal Agency: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: NH23IP922665 Award Year: August 2024 to July 2029 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Name of Contact Person: Rebecca Coyle, Executive Director Phone Number: (202) 552-0208 Anticipated Completion Date Completed April 2025 Views of Responsible Officials and Corrective Actions: In April 2025, a standardized procurement checklist and a formal review process were established and are maintained to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds.

Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during the transition and integration of operations with Global Communities. As a result, for some employees in the audit sample—particularly those who separated from the organization prior to the FY2025 attestation cycle—management was unable to retrieve employee-signed conflict of interest attestations for the immediately preceding period because the systems and files used to capture and retain those acknowledgments were no longer accessible, and responsible personnel were no longer employed. Management notes that, for a portion of the employee population, the FY2025 ethics training included a conflicts of interest section requiring employee acknowledgment; however, system limitations affected the ability to produce individual, employee-named attestations for all sampled employees in a format suitable for audit evidence. Planned Corrective Actions: Following the operational integration with Global Communities, management is strengthening controls over conflict of interest compliance by: (1) requiring conflict of interest acknowledgment at onboarding and on a periodic basis thereafter through a standardized process; (2) maintaining a centralized tracking mechanism to monitor completion status; (3) retaining documentation in a centralized repository/personnel record to ensure retrievability; and (4) performing periodic monitoring to confirm completion and retention across headquarters and field locations. These actions are intended to improve documentation, transparency, and ongoing compliance with conflict of interest requirements and standards of conduct.

II. Findings and Questioned Costs Related to Federal and State Awards Finding Number: 2025‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: - Mandatory documentation of quotes for applicable procurements - Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Action: The City ensures that debarment requirements for prime contractors and subcontractors are met prior to the use of federal funds. Moving forward, the City will expand compliance efforts to include all required parties. Staff will be educated on these requirements, and the City will work with engineers to ensure debarment language is included in project bidding documents and supplementary conditions. Proposed Completion Date: Immediately

2025-005 – Procurement Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations, procedures, and property and equipment management. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026

Federal Grantor: Department of Agriculture, Pass-Through: Nebraska Department of Education Program: Child Nutrition Cluster, Special Education Cluster Award No. and Year: 13898414/13897314/47600262900 and 2024, 24-6406-00-19-028-0001/24- 6408-00-19-028-0001/24-6411-00-19-028-0001/24-6412-00-19-028-0001/24-6418-132-28-0001P and 2024 Federal Assistance Listing Number: 10.553/10.555/10.559/10.582, 84.027/84.173 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Corrective Action: Management will work with the School Board to update the current procurement policy to include all requirements in 2 CRF 200. Name of Contact Person: Cindy Miserez, Controller (531) 299-9891 cynthia.miserez@ops.org Project Completion Date: June 30, 2026

Management's Response: The School District concurs with the recommendation. We recognize the importance of maintaining strong internal controls to ensure that all procurement activities are conducted in full compliance with Uniform Guidance (2 CFR Part 200) requirements. To address this recommendation, the District will enhance its existing procurement procedures by: 1. Developing and Formalizing Written Internal Controls. 2. Implementing Staff Training. 3. Strengthening Monitoring and Review Processes.

Community Project Funding/ Congressionally Directed Spending - Construction Community Project Funding – Assistance Listing No. 93.493 Recommendation: We recommend that the Organization formally documents its existing procurement and suspension/debarment practices in written policies that comply with 2 CFR Part 200. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The instance identified by the auditors was related to the Organization not having a written policy that documents its existing procurement and suspension/debarment practices. The Organization has outlined its response in the bullet points below: • The Organization implemented a formal, written policy that details their procurement and suspension/debarment practices and will follow this policy moving forward. Name(s) of the contact person(s) responsible for corrective action: Brian Holcomb, Controller Planned completion date for corrective action plan: Has been implemented If there are questions regarding this plan, please call Brian Holcomb, Controller, at 612-638-4900.

Audit Finding Reference: 2025-001 Planned Corrective Action: The Student Services and Food Service departments in Southwick-Tolland-Granville Regional School District will immediately ensure complete implementation of our internal control protocols regarding procurement. For any purchase that requires competitive procurement, we will conduct market research, obtain multiple quotes, or use the IFB/RFP process, if necessary. We will only engage in sole source procurement when we have determined that there is only one single provider of the good or service, and we will document that determination accordingly. We will enter into contracts with vendors when purchasing goods or services from them. We will use purchase orders to ensure that funds are encumbered and not over expended. Lastly, we will keep all procurement documentation on file, including quotes, bids, and sole source letters. Staff who engage in our purchasing process, including our Director of Student Services, our Director of School Nutrition, our Supervisor of Buildings and Grounds, and our Director of Technology will be retrained in our procurement protocols and will be expected to implement them immediately going forward. The Director of Finance and Operations will review all purchase requisitions to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 17, 2026 Person Responsible for Corrective Action: Nicholas Bernier Director of Finance and Operations Southwick-Tolland-Granville Regional School District

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Name of contact person: Michelle Richards – City Clerk/Treasurer Corrective Action: The city will develop a policy to provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and that no award, subaward, contract or agreement is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2027

Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: The District does not have a written procurement policy in place that satifies all provisions of Title 2 CFR Part 200.318 through 200.327. Responsible Individuals: Neil Breidenbach, System Manager Corrective Action Plan: The District will review the requirements of CFR sections 200.318 through 200.327 and update their procurement policy that meets the requirements. Anticipated Completion Date: December 31, 2026

Planned Corrective Action: Management will strengthen procurement policies, procedures, and documentation practices to ensure compliance with Uniform Guidance (2 CFR 200.318–200.327) and TxGMS general procurement standards. Actions will include: updating the procurement policy to clarify procurement methods and dollar thresholds; adopting a standardized procurement justification template for sole source determinations that requires documented rationale and supervisory approval; implementing a required procurement file checklist that documents the procurement method used, vendor selection process, quotes or bids obtained, and retained supporting documentation; instituting supervisory review and sign off of procurement classification and supporting documentation prior to award approval and payment; providing targeted training for Programs, Finance, and Procurement staff on procurement rules, sole source justification, and simplified acquisition documentation requirements; and performing a retrospective review of the two identified procurements to complete or document required supporting evidence and remediate any gaps. Finance will perform periodic testing of procurement files to verify adherence to the updated procedures and report findings to management and the Audit Committee. Responsible Parties: Kyle Bolls, Controller Ryan Parks, CFO Estimated Completion Date: September 30, 2026

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

US Department of Treasury Passed through Colorado Department of Human Services Federal Financial Assistance Listing 21.027 Award 24 IBEH 18932 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In our testing of procurement, suspension and debarment it was identified that the Organization did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326 implemented at the beginning of the fiscal year. In addition, there was no formal review of vendors to ensure they are not suspended or debarred prior to entering into transactions. Corrective Action Plan: Both of these two deficiencies will be dealt with through an updated procurement policy as well as a check list to ensure contracts comply with all federal guidelines. In addition, all processes needed to ensure compliance will be updated or created as needed. This recommendation has been implemented last fiscal year, however the deficiency remains as the corrective action wasn’t in place for the entire fiscal year. Responsible Individual(s): Karen DeGroot, Director of Finance Anticipated Completion Date: July 2025

Finding 2025-001 - Material Weakness Condition: Two (2) Next-Generation Facility Project (the Project) consulting contracts were procured in compliance with the Federal Transit Administration's (FTA's) procurement guidelines but did not conform with the Caltrans Local Assistance Procedures Manual (LAPM) Sections 10.01 and 10.1.9 of the LAPM, including not including a Public Interest Finding for the sole source procurement of the agreement, and the LeFlore group, LLC non-A&E consultant contract procurement did not comply with Section 10.3 of the LAPM. In addition, a Disadvantaged Business Enterprise goal was not requested nor completed as part of the advertisement for the project, which was required under Section 9.7.2 of the Caltrans LAPM. Recommendation: The Authority add additional language to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the Federal Highway Administration (FHWA). Management's Response: Management will ensure additional language is added to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the FHWA. The action will be completed with Board adoption of an updated Procurement Policies and Procedures Manual at or before its regular June 18, 2026, meeting. The contact person responsible for this action is Matthew Mauk, Executive Director, (530) 634-6880.

Corrective Action Plan Procurement Finding 2025-006 Roof Above will update the procurement policy to comply with Uniform Grant Guidance to include updated threshold criteria, publicizing bids, and checking for suspension and debarment of contractors. Roof Above will also update the corresponding procurement checklist to align with updated policy. Contact person responsible for corrective action: Kaedon Grinnell, Chief Program Officer Anticipated completion date: June 30, 2026

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of West Warwick’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The error will be corrected as of the beginning for fiscal year ending June 30, 2027. We will add the paragraph to our existing purchasing policy. This must be done by resolution and given the timeline that takes, we anticipate having this implemented the end of June 2026. Name of Contact Person Kristen Benoit, Finance Director Projected Completion Date 7/1/2026

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

NAMI Chicago acknowledges the finding and has revised the finance policy as of January 1, 2026 to clearly define micro-purchase thresholds and procedures for micropurchases, simplified acquisition thresholds and procedures for simplified acquisitions, formal procurement methods for use when transactions exceed acquisition threshold and noncompetitive procurement methods. Management will monitor procurement activity for compliance with the updated policy.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Water Conservation Grant Assistance Listing Number: 21.027 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 6, 2026 Planned Corrective Action: The District has designed and implemented policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. The Federal Programs Director and Procurement Clerk will check each vendor exceeding the formal procurement threshold for suspension or debarment.

Research and Development – Assistance Listing No. 20.000 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend that OSU STW and OSU CHS 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: OSU STW: The cause of this issue was primarily due to time constraints associated with completing work, which led to procurement procedures not being followed and purchases being initiated prior to obtaining proper authorization. To address this issue, the organization requires completion of a Ratification of Unauthorized Commitment form for all instances where proper procurement procedures were not followed. These instances are tracked and monitored by the Procurement Office. In addition, personnel have been re-educated on procurement requirements, with specific emphasis that a PO must be in place and approved prior to the initiation of work or commitment of funds. OSU CHS will reinforce existing procurement policies and procedures for federally funded purchases. Management will provide targeted communication and training to departments to ensure that applicable procurement requirements (such as obtaining competitive quotes or sole source justification) are followed when purchases exceed established thresholds. This communication will emphasize that total expected cost, including shipping and handling when known, must be considered when determining the appropriate procurement method. Name(s) of the contact person(s) responsible for corrective action: OSU-STW Jorge Guerrero, Norb Delatte, Jean Kerr-Hunter. OSU-CHS Michael Sauer Planned completion date for corrective action plan: OSU-STW Completed April 30, 2024, OSU-CHS May 31, 2026

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.