Corrective Action Plans

Auditor’s Recommendation: It is recommended that the Organization: Implement and enforce the updated procurement policy. Train staff on Federal procurement requirements. Implement a checklist or control mechanism to ensure all required documentation is retained for each procurement transaction. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and agrees with the recommendation. The Organization updated its procurement policy in February 2026 to align with applicable Federal procurement requirements. Management will implement and enforce the procurement methods established in the updated policy, provide training to relevant staff on Federal procurement requirements, and maintain the required supporting documentation for applicable procurement transactions going forward.

Management agrees with the finding. Management will spend additional time reviewing CFR section 200.318(i) for familarization. Assistance will again be requested to develop the additional proceudrement policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

The City of Mattawa appreciates SAO staff for help in identifying opportunities for improvement. The City will continue to update its procurement policies for compliance. The funding agency for the project was in agreement with utilizing the city’s yearly engineering procurement for services. The City now understands that, when it comes to federal funds, we would need to procure a separate engineering services proposal.

Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors' concerns regarding the retention and availability of historical procurement documentation. However, SWK notes that this finding relates primarily to documentation retention and retrieval rather than a failure to perform procurement activities or suspension and debarment verification. The primary issue resulted from the termination of the Unaccompanied Alien Children (UAC) Program during Fiscal Year 2025, which led to significant organizational downsizing, including the elimination of the Procurement Department. Historical procurement, solicitation, and bid documentation had been maintained within a procurement software platform administered by that department. Following program closure and the departure of procurement personnel, the software platform was decommissioned, resulting in certain historical procurement records no longer being readily accessible during the audit. SWK did, however, provide evidence that vendors selected for procurement actions were screened for suspension and debarment in accordance with federal requirements. Additionally, two of the six contracts exceeding the simplified acquisition threshold represented renewals of previously procured contracts; however, complete historical bid files could not be retrieved for audit review. SWK further notes that as of the date of this corrective action plan: • The UAC Program has been terminated. • SWK no longer maintains a dedicated Procurement Department. • SWK has no active federal procurement contracts over $250,000 requiring formal solicitation procedures. • No questioned costs were identified by the auditors. • The auditors concluded that services and goods purchased under the reviewed contracts were allowable and supported program operations. Corrective Actions Although the circumstances surrounding this finding relate to historical records associated with a discontinued program, SWK has implemented the following actions to strengthen document retention and procurement oversight for any future federally funded procurements: 1. Centralized Procurement Record Retention SWK has established a requirement that all procurement-related documentation, including solicitations, bid responses, evaluations, vendor selection justifications, contract approvals, and suspension/debarment verifications, be maintained in a centralized electronic repository controlled by Finance and Administration, rather than an individual department or software administrator. 2. Procurement Documentation Checklist SWK will continue to utilize a standardized procurement checklist for any future procurement transactions subject to federal procurement requirements. The checklist will ensure required documentation is retained and readily accessible for monitoring or audit purposes. 3. Enhanced Document Archiving Procedures Prior to the discontinuation of any program, department, or software platform, SWK will perform a records-retention review to ensure all procurement and contract documentation subject to federal record retention requirements is archived and preserved. 4. Management Oversight The Chief Administrative Officer will be responsible for periodic reviews of procurement files to verify that required documentation is complete and retained in accordance with federal and organizational requirements. 5. Future Procurements SWK will review and update its documented procurement procedures to conform to applicable federal statutes, the procurement requirements identified in 2 CFR Part 200, and the new federal procurement thresholds as of October 1, 2025. Further, SWK will institute a centralized purchasing function under Finance and Administration to facilitate the review of procurements to ensure compliance with both 2 CFR Part 200 and the terms and conditions of awards. This function will ensure the enforcement of the procedures mentioned above by: - Conducting vetted vendor onboarding and ongoing management via periodic reviews to verify that non-federal entities, contracts, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federal programs - Obtaining appropriate documentation of multiple vendor quotes and/or sole source justification for small purchases greater than the micro-purchase threshold, but below the simplified acquisition threshold - Managing, following, and documenting the simplified acquisition procedures for purchases greater than or equal to the simplified acquisition threshold Expected Completion Date: In process and to be completed by December 31, 2026 Ongoing monitoring and compliance reviews will continue for any future procurement activities. Status Corrective action substantially implemented. Upon review of current FY2026 purchases and due to the closure of the UAC Program, the risk associated with this finding has been significantly reduced. The corrective actions above are designed to ensure appropriate documentation retention and compliance should future federally funded procurement activities occur. Responsible Officials: Chief Administrative Officer, Marisol Cervera

The District will draft, approve, and implement written procurement procedures for federal-award procurements and communicate those procedures to the Board of Trustees, management, and personnel or consultants involved in procurement and contract administration.

Finding 2025-006 I. Procurement, Suspension and Debarment Procurement Approval and Executed Agreement Compliance Management agrees with the finding and has outlined the following corrective actions: • Obtain Board approval for a new intergovernmental agreement for Chicago Police Department at the September 2026 board meeting. • Complete a full review of 2025 and 2026 procurement files by the end of Q1-2027 to ensure all required Board approvals and executed agreements are retained. • Strengthen internal workflows to prevent procurement actions from proceeding without verified approvals and executed agreements through inclusion of a new checklist which will be reflected in an updated standard operating procedures (SOP). • Provide refresher training to procurement staff on 2 CFR 200 documentation retention requirements by December 2026. Suspension and Debarment Compliance Management concurs with the findings and will implement: • Semiannual targeted training to reinforce staff responsibilities for verifying vendor eligibility and documenting compliance to begin December 2026. • Enhanced managerial monitoring through a standardized checklist to ensure required suspension/debarment checks are completed and retained before issuing purchase orders. Implemented January 2027. Responsible for Corrective Action: Tamika Carson, Director of Procurement; Sheila Johnson, Deputy Chief Procurement Anticipated Completion Date: Q1-2027

Views of Responsible Officials: Management acknowledges the finding and agrees that certain procurement files requested during the audit could not be located or produced in complete form. Management believes that procurement activities were conducted in accordance with organizational policies and applicable Federal requirements at the time the transactions occurred. However, following the rapid and significant reductions in force resulting from the termination of U.S. Government funding, not all procurement responsibilities and records were fully transitioned to remaining personnel. Functions were discontinued on an accelerated timeline, resulting in procurement documentation being maintained across multiple systems and storage locations rather than within a single centralized repository. Consequently, certain supporting records could not be readily retrieved during the audit.Management has initiated a comprehensive revision of its procurement policy and related procedures. The revised policy will require centralized storage of procurement documentation and establish clearer accountability for records management. In addition, roles and responsibilities will be more clearly defined within the organization's current structure to promote consistency, continuity, and accessibility of procurement records going forward.

Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the federal law and standards identified in 2 CFR 200.318 through 2 CFR 200.327. A procurement policy that aligns with these federal requirements is currently being developed. Name(s) of the contact person(s) responsible for corrective action: Lynn Lowrie Planned completion date for corrective action plan: Policy has been drafted and is under internal review. This will be finalized during the November 2026 Board Meeting.

2025-002: Procurement and Suspension and Debarment Statement of Condition: The Organization did not appropriately monitor expenditures for the vendor tested to trigger verification of the vendor status of suspension or debarment prior to the expenditures reaching the $25,000 covered transaction threshold. Additionally, the Organization’s procurement policy did not fully comply with the federal procurement standards outlined in the Uniform Guidance. Management Response and Corrective Action Plan: The Organization has revised its existing vendor policies and procedures to ensure it complies with the federal procurement standards outlined in the Uniform Guidance, including the testing of vendor status for suspension or debarment prior to engaging in any federal award-funded transactions with excluded parties. Responsibility of: Controller, Jennifer Laret and Chief Financial Officer, Jill Borovansky Planned Implementation Date of Corrective Action Plan: 2026 Audit

Finding Number: 2025-004 Finding Title: Federal Awards Internal Control Policy and Procedures 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: County management will develop and formally adopt a federal expenditures policy to establish procedures for administering and monitoring federal awards in accordance with Uniform Guidance requirements. The policy will address internal controls over compliance, allowable costs, reporting requirements, record retention, and other applicable federal compliance requirements. Management will also communicate the policy to appropriate personnel responsible for administering federal programs. 3. Official Responsible for Ensuring CAP: Steve Ewing, County Administrator, is the official responsible for ensuring corrective action plan. 4. Planning Completion Date for CAP: 12/31/2026 5. Plan to Monitor Completion of CAP: County management will review the policy periodically to ensure it remains current with federal requirements and will monitor compliance with the policy through the administration and oversight of federal programs.

Finding 2025-001 - COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Norfolk County Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: During our testing as it related to compliance with procurement we noted that an expense for engineering services for the Well #10 Permitting Project services charged to the major program would have required a formal bidding process as the project exceeded the simplified acquisition threshold of $250,000. Context: The Town had a ARPA project 1123 for well#l0 permitting project that they relied on a request for qualifications from 2011 for engineering services related to Town wide drinking water. The Well#l0 project was submitted on 12/20/22 for approval by Norfolk County. It is the auditor's professional judgment that separate procurement procedures should have been performed as the RFQ was approximately 11 years old and this was a new project. Although services are exempt under State procurement requirement, Federal Procurement rules would have required procurement procedures. Under Federal Procurement requirements expenses of $250,000 or more require a formal bid process. As the project costs and estimates at the time of the project exceeded $250,000, the Town should have performed formal bid procedures for this service. Questioned Costs: Based on vendor expenses charged to the grant in FY 2025 the total questioned costs were $54,060.65. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is a risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Itle11tijicatio11 as a Repeat Finding: 2024-002 Recommendation: Going forward, the Town of Bellingham should consider a separate bidding process for expenses related to federal grant awards. Responsible for Corrective Plan: CFO Estimated Completion Date: December 2026 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement, Suspension and Debarment Condition: The Village's procurement policy does not comply with the procurement requirements of the Uniform Guidance. The policy does not include written conflict of interest standards applicable to employees, officers, or agents involved in the selection, award, or administration of contracts funded with federal awards. The policy does not establish a simplified acquisition threshold for formal procurement procedures, to align with the federal procurement methods established under the Uniform Guidance. The Village contracted with a third-party administrator who provided the appropriate services related to procurement for this grant program. Corrective Action: Management agrees with the finding and will make efforts to implement a formal procurement policy. Person Responsible For Corrective Action: April Bruhn, Clerk/Treasurer Anticipated Completion Date: December 31, 2026

Finding 2025-002 Finding Type: Material Weakness in Internal Control Over Compliance and Instance of Immaterial Noncompliance Compliance Requirement: Procurement and suspension and debarment Corrective Action Planned Willame􀆩e Health Council will develop, approve, and implement wri􀆩en procurement policies and procedures that conform to the Uniform Guidance procurement standards outlined in 2 CFR §200.318 through §200.327 Procurement Standards. Person(s) Responsible • Josie Silverman-Méndez, Executive Director • Julie Bennett, Finance Manager Anticipated Completion Date • October 31, 2026

Finding No. 2025-002: Procurement- Compliance Finding and Significant Deficiency in Internal Control over Compliance EPIC acknowledges that documentation confirming vendor suspension or debarment was not present in various vendor files for FY25. Corrective Action Plan: EPIC has updated its vendor onboarding process to include confirmation of all new vendors prior to being awarded contracts. In addition, all current vendors will be confirmed eligible to receive federal funds during the RFP process for each subsequent project award. Contact Person Responsible for Corrective Action: Thomas Sperti, Chief Financial Officer

Community Project Funding / Congressionally Directed Spending – Assistance Listing No. 17.289 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Assistance Listing No. 10.561 Recommendation: We recommend management revise procurement policies to fully align with Uniform Guidance requirements and strengthen procedures to ensure procurement decisions, management approvals, competitive procurement documentation, and suspension and debarment verifications are consistently performed, documented, and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed and updated the financial policies and Procedures Manual as of 01/2026. Procurement procedures have been strengthened. Federal procurement documentation requirements have been incorporated into our process. Suspension and debarment reviews are now being conducted and documented for all new vendors. Procurement files now include approval and compliance documentation. Name(s) of the contact person(s) responsible for corrective action: Stacia Russell Planned completion date for corrective action plan: 01/01/2026

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Ilwaco January 1, 2025 through December 31, 2025 This schedule presents the corrective action the Port is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The Port did not have adequate internal controls for ensuring compliance with federal procurement requirements, and did not comply with federal suspension and debarment and wage rate requirements. Name, address, and telephone of Port contact person: Tina Hayes, Executive Director 165 Howerton Way SE Ilwaco, WA 98624 (360) 642-3143 Corrective action the auditee plans to take in response to the finding: The Port will establish internal controls to comply with federal procurement requirements, including establishing written procurement procedures that conform to federal procurement standards in Uniform Guidance (2 CFR § 200.318-327). The Port will strengthen its internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs and maintain documentation demonstrating compliance with this requirement. The Port will strengthen internal controls to ensure compliance with federal wage rate requirements. This should include implementing effective monitoring processes to collect and review all weekly certified payroll reports from subcontractors. The Port will provide training to ensure staff overseeing compliance with federal program s are aware of all applicable requirements. Anticipated date to complete the corrective action: December 31,2026

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2025-003 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants – Assistance Listing No. 14.251 Recommendation: We recommend the Organization strengthen controls to ensure procurement documentation is consistently obtained, retained, and reviewed for compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has strengthened procurement procedures to ensure required documentation is consistently obtained, reviewed, and retained to support compliance with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Jeff Fournier, Finance Director Planned completion date for corrective action plan: June 30, 2026

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirements: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Description: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Health and Human Services None 93.243 - Substance Abuse and Mental Health Services Projects of Regiona l and National Significance 5H79SM088573-02 (Year: 2025) $80,321 A review of expenditures cha rged to the Substance Abuse and Mental Health Services Projects of Regional and National Significance program revea led that the School District's internal control procedures were not operating appropri ately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Procedures have been reviewed with program and department leaders to ensure that all expenditures have proper approval before submitt ing for payment. Expenditures without proper approval will be returned to the responsible department. Board Policy DJED has been reviewed with all department heads to ensu re understanding of policy and requirements for obtaining multiple quotes for certain thresholds. Additional procedures will be added to how vendors are verified of being suspended or debarred. Currently the vendor is verified of not being suspended or debarred when they are added to the accounting system and then once annually if they have been paid $25,000 or more during a certain time frame. Additional procedures will be added to have the vendors verified at year end who have been paid $25,000 or more with federal fun ds. Estimated Completion Date: August 31, 2026 Contact Person: Stephanie Clark, Chief Financial Officer Telephone: 912-876-4854 Email: sclark@liberty.k12.ga.us

FA 2025-002 Improve Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Description: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agricu lture Georgia Department of Education 10.553 - School Breakfast Program; 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $40,701 A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Corrective Action Plans: Procedures have been reviewed with program and department leaders to ensure that all expenditures have proper approval before submitting for payment. Expenditures without proper approval will be returned to the responsible department. Board Policy DJED has been reviewed with all department heads to ensure understanding of policy and requirements for obtaining mult iple quotes for certain thresholds. Guidelines have been reviewed with the program manager and school nutrition bookkeeper to ensure all expenditures are recorded in the correct fiscal years. Estimated Completion Date: August 31, 2026 Contact Person: Stephanie Clark, Chief Financial Officer Telephone: 912-876-4854 Email: sclark@liberty.k12.ga.us

Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Additionally, City personnel will make every effort to familiarize themselves with the rules of the Federal Awards programs. Responsible Person: Magdlin Wurst Anticipated Completion Date: December 31, 2026

Audit Finding Reference: 2025-003 Special Education Planned Corrective Action: For all special education procurements, a formal sole source justification statement will be documented and retained with the purchase records. Planned Implementation Date of Corrective Action: School year 2026-2027 Persons Responsible for Corrective Action: Ronnie Kessler, Director of Student Services Director Kirsteen Patterson, Director of Finance and Operations

Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). The Organization concurs with the prior year (2024-003) and current year renumbered recommendation (2025-003),and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Financial Policies – May 2025. Completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Initiated use of MTPF, and process implementation of Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal. C. HRSA Policies – July 2025. Developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. Informed the Board about the progress of the Organization’s policy framework, including the above policies. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the application of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). E. Updated procurement processes for emergency disaster recovery and support of community needs, including MTF documentation. Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date Finding No. 2025-003: Procurement Policies Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.

Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted written standards of conduct governing actual, potential, and perceived conflicts of interest involving employees and governing body members who participate in the selection, award, or administration of contracts supported by federal funds. To address the finding, the Town will develop a written conflict of interest policy that complies with applicable federal requirements, including 2 CFR § 200.318(c)(1). At a minimum, the policy will: 1. Define actual, potential, and perceived conflicts of interest and prohibited conduct; 2. Identify the employees, officials, and governing body members subject to the policy; 3. Require prompt written disclosure of relevant financial interests and other potential conflicts; 4. Establish procedures for reviewing, documenting, and resolving disclosed conflicts; 5. Require affected individuals to refrain from participating in matters in which a conflict exists; 6. Establish appropriate disciplinary or corrective measures for violations; 7. Require periodic written conflict-of-interest acknowledgments and disclosures; and 8. Address the retention of acknowledgments, disclosures, determinations, and related compliance documentation. The proposed policy will be presented to the Town Council for formal consideration and adoption. Following adoption, the Town will distribute the policy to applicable employees and governing body members and provide appropriate training or written guidance regarding their responsibilities. The Town will retain completed acknowledgments, disclosures, and documentation of any conflict determinations in accordance with its applicable record-retention requirements. Management will periodically review the policy and related procedures to help ensure continued compliance with federal award requirements. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026. Current Status The Town currently does not have a written conflict of interest policy.

Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with vendors, contractors, or subrecipients. Criteria Organizations that receive federal funding are generally required, under 2 CFR § 200.318–200.327 (Uniform Guidance), to: • Maintain written procurement procedures that conform to applicable federal, state, and local laws; • Ensure procurement transactions are conducted in a manner providing full and open competition; • Verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded from participating in federal programs, per 2 CFR § 200.214 and 2 CFR Part 180. Cause The Institute has not formalized its procurement practices in a written policy and staff is not currently required to check suspension and debarment status as part of the vendor selection or contracting process. Effect Without a written procurement policy, the Institute lacks a consistent, auditable standard for procurement decisions, increasing the risk of non-compliance, favoritism, or inconsistent practices across departments. The absence of suspension and debarment checks creates risk that the Institute could enter into agreements with parties who are legally excluded from receiving federal funds, potentially resulting in disallowed costs, reputational harm, or loss of funding. Recommendation The Institute should develop and formally adopt a written procurement policy that addresses methods of procurement, competition requirements, documentation standards, and conflict-of-interest provisions consistent with 2 CFR § 200.318–200.327. The Institute should also implement a documented procedure requiring suspension and debarment verification (via SAM.gov or equivalent) for all vendors, contractors, and subrecipients prior to contract execution, and retain evidence of this check in procurement files. Management Response Management agrees with the finding and recommendation. The Institute is formalizing its procurement practices in a written procurement policy consistent with applicable Uniform Guidance requirements. The policy addresses procurement methods, competition, documentation, conflicts of interest, and suspension and debarment requirements for procurements in accordance with federal regulations. Action Taken The Institute contracted with Visual Compliance to assist with verifying vendors against all available U.S. debarred and suspended lists before entering into covered contracts or agreements with vendors, contractors, or subrecipients. The Institute has developed and approved a Suspension and Debarment policy and staff are required to check suspension and debarment status as part of the vendor selection or contracting process. The Institute is developing a written procurement policy. Evidence of the verification will be retained with the applicable procurement or agreement documentation.

Finding Reference This corrective action plan relates to audit finding 2025 001 as reported in the schedule of findings and questioned costs. Contact Persons Dwayne Shaw, Executive Director, and Michelle Wright, Office Manager , are responsible for implementing and monitoring the corrective actions, maintaining related policies and procedures, and reporting status to those charged with governance. (207) 483-4336 Management’s Response / Concurrence Management agrees with the finding. The organization acknowledges that it does not currently have written policies and procedures addressing certain required Uniform Guidance compliance areas. Planned Corrective Action Management will develop, approve, and implement written policies and procedures designed to comply with applicable Uniform Guidance requirements, including policies over allowable costs/cost principles, cash management, and procurement, including suspension and debarment. Management will also communicate the new policies to relevant personnel and provide training as needed to support consistent implementation. Anticipated Completion Dates Management will finalize and implement the corrective action plan on or before September 30, 2026.