Corrective Action Plans

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2024 FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation's policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation's contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the School Corporation's procurement policy is being followed for all procurement thresholds. Management will perform a periodic check of federal fund disbursements to see if any vendors exceed procurement or suspension and debarment thresholds on an annual basis to ensure compliance with federal and state procurement guidelines. The School Corporation will ensure that all contracts exceeding $25,000 include a suspension and debarment clause and will verify that the vendor is not suspended or debarred prior to entering into the contract. Responsible Party and Timeline for Completion: The Food Service Department has already implemented these changes as the issue was not present in fiscal year 2024.

Identifying Number: 2024-003 Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Corrective Action: Management has developed the following procedures to ensure that vendors are not suspended or debarred: • All current vendors will be checked against Sam.gov on a quarterly basis. • All vendors receiving Federal funds of $25,000 or greater will be checked prior to completion of any purchase requisition. • All vendor applicants will be required to sign a Certified document that they are not suspended or debarred along with the Vendor App. • All bids will have a Certified document included for vendors to submit that declares they are not suspended or debarred. Anticipated Completion Date: December 2024 (for the year ending June 30, 2025). Contact Person: Stacy Swenson, Director of Purchasing 816-321-5016 Stacy.swenson@nkcschools.org

CORRECTIVE ACTION PLAN 2024-002 – Written Policies Required by Uniform Grant Guidance Corrective Action: Institute a formal grant policy in accordance with Uniform Grant Guidance. Responsible Party: Finance Director Date to Complete By: 1-31-25

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely with USDA representatives as we have moved through the program. A budget for all costs was approved as part of the grant award. All invoices, including all engineering fees, are approved directly by our assigned Area Specialist. The project costs are currently all within budget. The Village of Lexington will ensure that engineering services follow correct procurement procedures in any future grant program it is awarded.

Re: Finding 2024-001: Procurement (50000) Nutrition Services currently uses US Foods for the purchase of various commercial food items throughout the year (candy, chips, soda, bread, hotdogs, popcorn, coffee, hot cocoa, churros, cookies, etc). A vast majority of the purchases are for non-program foods for catering or Snack Bar Sales at Fred Kelly Football Stadium. Occasionally, US Foods is used to purchase specialty items for students with food allergies (i.e. gluten free) and baby food for students that require a pureed diet. Nutrition Services compares prices between US Foods and Smart and Final periodically throughout the year. Smart and Final purchases are made in store and Nutrition Services would have to provide pictures of price tags on the shelf at Smart and Final to show compliance with this request. Nutrition Services requested a price quote for products purchased through US Foods. Unfortunately, the company representative told us their prices are variable based on the market and could change weekly. Nutrition Services would only be able to provide auditors of screenshots ofUS Foods online ordering portal, which would consist of hundreds of pages given the expansive foods available. To correct the finding, Nutrition Services will do the following: 1. Request piggybackable formal bid options from US Foods. To that end, the Nutrition Services and Purchasing directors will seek board approval no later than March 1, 2025. 2. Take necessary steps to increase micropurchase threshold to $50,000. 3. Consider opening a Purchase Order with Sysco Foods to spread the micropurchases to another online retailer, thus mitigating the issue of in-person shopping and price comparisons. 4. Work with Purchasing Department to ensure open Purchase Orders do not exceed $50,000 for any vendor that does not have formal procurement in place. To that end, the Nutrition Services Accounting Technician and the Purchasing Supervisor will review quarterly expenditures for all open purchase orders effective December 1, 2024.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.559 2024-001 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, Tammy Fredrickson. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Tammy Fredrickson, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

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. This will be completed by Ashley Simmons, Accounts Payable Clerk by 6/30/2025.

Management response/corrective action plan: Efficiency Maine has delegated a staff person to work with outside counsel to revise our procurement policy as it relates to federal funds in order to properly address all requirements of the Uniform Guidance.

2024-002: Written Procurment, Suspension and Debarment Policy Finding Condition - The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included in the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award and adminstration of Federal grant contracts. Corrective Action Plan - Even though the Town didn't have a formal written policy in place regarding the search for suspended or debarred vendors/contractors, the Town did do the SAM's search before signing agreements with contractors on each of the Federal Grant projects that were in place during the year. A policy was written and signed on September 2, 2024.

Management at the Central Maine Growth Council is aware of its responsibility under 2 CFR 200.516(a) as it relates to the requirements to perform control activities related to suspension and debarment. • All recipients of expenditures under federal grants will be compared to the Office of Inspector General’s Exclusion Database to help ensure they are permitted to receive federal funding. This verification process will be documented and retained. • A written formal procurement policy and conflict of interest policy will be established. Responsible party: Garvan Donegan, Director of Economic Development and Strategic Projects (207) 680-7300 Anticipated completion date: December 31, 2024.

October 17, 2024 Cognizant or Oversight Agency for Audit: Department of Elementary and Secondary Education (DESE) Worcester Cuftural Academy Charter Public School respectfully submits the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA, 01581 Audit period: July 1, 2023 through June 30,2024. The findings from the October 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2024-001 Massachusetts Teachers’ Retirement System (MERS) Enrollment. Recommendation: Management should ensue that proper controls are in place and operating effectively to ensure that that all MTRS eligible employees are fully enrolled within thirty days of their start date. We recommend management add enrollment of MTRS for eligible employees to its onboarding checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-002 Massachusetts Teachers’ Retirement Board (MTRB) Remittances Recommendation: Management should ensure that proper controls are in place and operating effectively to ensure all MTRS payroll withholdings are remitted timely. We recommend management add MTRB remittances to its monthly closing checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-003 Written Procurement Policy Recommendation: Management revise their poiicy to comply with current standards under the Uniform Guidance. Action Token: We concur with the recommendation, and it will be implemented effective January 1, 2025. If the Department of Elementary and Secondary Education (DESE) has questions regarding this plan, please call Erika Browning, 508-347-0252. Sincerely yours, Signature: Title: Tina Krasnecky, VP of Finance

Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025

The Purchasing department will develop and maintain written procurement procedures requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micro purchase threshold require multiple quotes and that these quotes are properly documented as evidence. “Small purchases” are those where the total dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. Purchasing department staff will be trained on this procedure and the District will adopt a board policy to address this procedure. The contact person is Philippa Townsend and the anticipated completion date is 11-1-2025.

As of November 1, 2024, the District will have implemented a process to determine the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds.

The District will review the requirements of 2 CFR Section 200.213 and ensure that procurement procedures are being followed and perform a review of the eligibility of potential vendors to ensure they are eligible to participate in Federal assistance programs.

Management’s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance/ShelterCare 2. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 3. The anticipated completion date: a. New processes will be implemented by 11/1/2024.

Management Response: Management concurs with the finding. During the audit period, procurement documentation was not consistently maintained in a centralized manner sufficient to demonstrate full compliance with Uniform Guidance procurement requirements, although management believes procurement decisions were generally made in the best interests of the Organization. Since FY2023, SWIWC has significantly enhanced its procurement practices by implementing updated procurement policies aligned with Uniform Guidance, standardized procurement checklists, documented quote requirements, vendor selection documentation, SAM.gov verification procedures, approval workflows, and centralized procurement files. Staff have also received additional training regarding procurement documentation and federal compliance requirements. Management believes these corrective actions establish a substantially stronger procurement control environment and will support continued compliance with federal procurement standards. Anticipated Completion Date: Implemented 6/30/2026; ongoing monitoring. Responsible Party: Chief Financial Officer and Director of Finance, with applicable Program Managers responsible for providing programmatic documentation.

Condition: Controls were not sufficient to ensure that management has written policies and procedures surrounding procurement that align with Federal Procurement Standards outlined within the Uniform Guidance. Further, controls were not adequate to ensure that the history of procurement decisions was documented. Additionally, controls were not sufficient to ensure checks for suspension and debarment were performed and documented before entering into a covered transaction with third parties. Planned Corrective Action: The Organization will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2024

Procurement Recommendation: We recommend that management develop, adopt, and implement written procurement and conflict-of-interest policies that comply with Uniform Guidance requirements. These policies should address procurement standards, including methods of procurement and oversight, and establish standards of conduct governing conflicts of interest for employees, officers, and agents involved in the administration of federal awards. Management should also ensure that these policies are communicated to relevant personnel and applied consistently. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2024 new maintenance staff was employed 3 bids are required for capital projects. If one contractor has personal relationship with employee conflict of interest form is filed. Name(s) of the contact person(s) responsible for corrective action: Kristin Cowan Planned completion date for corrective action plan: July 2024

Finding No.: 2023-025 AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1: The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Finding No.: 2023-025, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance is warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Finding No.: 2023-025, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 2: DPW, TSD-Highway Branch and the Procurement Services Division respectfully disagrees with this finding. A review of the procurement file confirmed that the Bid Opening Summary Sheet was maintained as part of the official bid package and procurement record for this solicitation. Procurement Services has located the Bid Opening Summary Sheet and confirmed that it accurately documents the bid opening results in accordance with applicable procurement requirements. The document remains in the procurement file and is available for review. A copy has been provided for reference. Based on the existence and availability of this document, Procurement Services respectfully requests reconsideration of this finding. The supporting documentation identified as missing was maintained within the procurement file and was available for audit review. While Procurement Services disagrees with this portion of the finding, it remains committed to maintaining complete procurement records and will continue reviewing internal recordkeeping practices to ensure procurement files are organized, complete, and readily accessible for audit and compliance purposes. Proposed Completion Date: Ongoing

Finding No.: 2023-019 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (G. Cruz): The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance are warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Condition 2 (E. Cabrera / N. Karakaya / G. Cruz): For TAP sample selections (FG26100012, FG26100002, 1901210068, 2001210031, and FG26100021), the Office of Grants Management (OGM) agrees with this finding and concurs that a formal procedure for verifying suspension and debarment status was not documented during FY2023, especially as this procurement aspect was not enforced by the Division of Procurement Services. However, management is not aware of any instances in which the listed contracts or subawards were issued to entities that were suspended, debarred, or otherwise excluded from participation in federally funded programs. All goods and services were received, and all expenditures were incurred for allowable program purposes. Accordingly, OGM believes the finding represents a control and compliance deficiency rather than an instance of unallowable costs. OGM has begun implementing procedures requiring SAM.gov verification and retention of supporting documentation prior to entering into covered transactions, especially due to a more recent procurement purchase. OGM kindly seeks the auditor’s discretion in changing the questioned costs to the amount of zero, due to it being more of an internal control issue rather than an allowability issue. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: For the CIP sample selection (FC26050009), The Capital Improvement Program (CIP) agrees with the finding and that it did not verify if the firm in question was excluded or disqualified at the time of procurement. The Division of Procurement Services has recently begun requiring agencies to provide search results on SAM.gov Exclusions for the processing of contracts moving forward. CIP will follow this new protocol and include it in the standard documents for all construction and non-construction contracts. To prevent recurrence, CIP will implement the following actions: • CIP will include “Verification of suspension and debarment status” as a required item under Contract Documents on CIP’s contract templates • Staff Training and Awareness o CIP will train staff members to utilize the SAM.gov Exclusions page to search for vendors and print proof of verification. o CIP will ensure that all staff members are familiar with the new protocol with Procurement Services. • Monitoring and Verification o CIP will conduct reviews of new contracts and processing change orders to ensure that this new requirement is met. Additionally, the Procurement Services Division agrees that vendor eligibility was not verified in accordance with 2 CFR Part 180 prior to the covered transactions identified by the auditors. To address this issue, Procurement Services has incorporated suspension and debarment verification into its procurement review process. For federally funded covered transactions, expenditure authorities will be required to provide documentation from the System for Award Management (SAM.gov) verifying that the vendor is not suspended or debarred. This documentation must be submitted with the procurement package and retained in the procurement file prior to award. Procurement Services will review the documentation as part of its procurement review process and will provide additional guidance to procurement personnel and expenditure authorities regarding federal suspension and debarment requirements. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: These measures are intended to improve compliance with federal requirements and strengthen procurement documentation and oversight. Proposed Completion Date: Ongoing

Finding No.: 2023-010 AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1: The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Finding No.: 2023-010, continued AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance are warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Condition 2: CNMI NAP agrees with this finding. The issue occurred because the previous policies and procedures did not fully document the three allowable verification methods under 2 CFR 180.300 for covered transactions ≥ $25,000. As a result of repeat findings, CNMI NAP developed and implemented the updated “SOP for Procurement of Goods and Servicesv.3”, which explicitly requires verification of vendors in the SAM.gov exclusions list prior to award (Section 4.1 and 4.3) and after contract execution, in full compliance with 2 CFR 200.214 and 2 CFR 180.300. This SOP was approved and effective 5/1/25 and is available for review upon request. Additional step taken by CNMI NAP is to continue adhering to the “CNMI NAP Suspension and Debarment SOP” that requires a screen-print documentation and annual reviews. This SOP was approved on 9/24/24 and is available for review upon request. Finding No.: 2023-010, continued AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: To prevent recurrence, CNMI NAP will deliver targeted training to all procurement, finance, and program staff on the updated SOPs, continue quarterly internal reviews of procurement files using new Google Sheet tracking system to verify ongoing SAM.gov compliance. Full staff training and first quarterly review will be completed by 9/30/26. Additionally, Procurement Services agrees that vendor eligibility was not verified in accordance with 2 CFR Part 180 prior to the covered transactions identified by the auditors. To address this issue, Procurement Services has incorporated suspension and debarment verification into its procurement review process. For federally funded covered transactions, expenditure authorities will be required to provide documentation from the System for Award Management (SAM.gov) verifying that the vendor is not suspended or debarred. This documentation must be submitted with the procurement package and retained in the procurement file prior to award. Procurement Services will review the documentation as part of its procurement review process and will provide additional guidance to procurement personnel and expenditure authorities regarding federal suspension and debarment requirements. These measures are intended to improve compliance with federal requirements and strengthen procurement documentation and oversight. Proposed Completion Date: Completed

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when racticable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Ida R. Kilcullen Director Bureau of Curriculum & Instruction Ministry of Education Contact: 680-488-2547 Email: ikilcullen@palauschools.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org