Corrective Action Plans

Compliance Requirement Procurement Criteria Under 2 CFR 180.995, the School District must not enter into covered transactions with parties that are suspended or debarred. For covered transactions (generally at or above the simplified acquisition threshold), the School District must verify that vendors are not suspended or debarred by (1) checking SAM.gov, (2) collecting a vendor certification, or (3) adding a contractual clause that the vendor is not suspended or debarred and maintaining documentation of the verification. Additionally, under 2 CFR 200.318(h), the School District must maintain effective internal controls over procurement to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition During testing and confirmed with management at the School District, it was determined that the School District does not verify that vendors were not debarred or suspended. Cause The School District’s procurement procedures do not require or are not consistently followed to perform and retain documentation of suspension and debarment checks for covered transactions. Effect Without controls to verify and document vendor eligibility, the School District is at risk of expending federal funds with vendors that are suspended or debarred, resulting in noncompliance with federal requirements. This could lead to questioned costs, repayment obligations, and reputational risk. Recommendation The Bonadio Group recommended that the School District strengthen its internal controls over the procurement requirement regarding suspension and debarment requirement by implementing the following actions: (a) Update written procurement procedures to clearly require documented verification before entering any covered transactions. (b) Require procurement staff to document verification at the time of award and to retain the documentation in the procurement file. (c) Integrate a system of controls, where feasible, that prevents a purchase order or contract from being finalized unless proof of suspension/debarment verification has been uploaded. (d) Provide reoccurring training to procurement, finance and grant management staff regarding federal suspension and debarment requirements and proper documentation practices. (e) Implement periodic monitoring or internal reviews to ensure that the verification process is consistently followed and address any deviations promptly. View of Responsible Officials The School District will institute additional procedures to ensure that vendors are not debarred or suspended. Response We are in agreement with the recommendation and will be creating a federal funds procedural manual to address the issues above. Anticipated Completion Date This will be corrected by 6/30/26. Person Responsible Stephanie Fanning, Assistant Superintendent for Business

Date: February 9, 2026 FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Paula Powers, Food Service Coordinator Contact Phone Number and Email Address: 812-347-3905 ppowers@nhcs.k12.in.us Views or Responsible Official: We concur with the findings. Description of Corrective Active Plan: The Food Service Coordinator will verify Sam.gov to confirm a contractor is not suspended or disbarred before awarding a contract every 12 months. For small purchases, quotes will be obtained and retained with the claims for that payment. Anticipated Completion Date: March 2026

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-006 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the child nutrition cluster federal program. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it 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 is in the process of reviewing and updating its policies and procedures relating to procurement, 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 methods of procurement and maintaining appropriate documentation. Official Responsible – Kathleen Heider, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Kathleen Heider, Finance Director, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, suspension, and debarment requirements.

Information on the federal program: Subject: Child Nutrition Cluster, Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: Child Nutrition Cluster Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. 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. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micropurchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not review procurements done by the food service management company to ensure that proper procurement policies were followed. The School Corporation did not ensure that the food service management company did not use suspended or debarred vendors. During the audit period, we noted two small purchases for which the School Corporation did not have evidence of obtaining multiple quotes or documented rationale for selecting the vendor. Only the final invoice, purchase order, and quote from the selected vendor were available. During fiscal year 2024, we noted that for one of the three vendors tested, the correct procurement method was not followed. Purchases from the vendor were in excess of $150,000 during the fiscal year, requiring the simplified acquisition procurement process; however, the School Corporation applied the small purchase procurement process. The purchase was for equipment at two different buildings. The School Corporation issued two requests for quotes, one for each school, and treated them as separate procurements. However, as the purchases were similar in nature, the requests for quotes were dated the same day and sent to the same vendor, this should have been treated as one procurement in aggregate. The School Corporation did not have support for public advertisement, requests for formal sealed bids, or formal documentation for the basis of award. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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, we noted two vendors out of three that were sampled, over the $25,000 suspension and debarment threshold for which the School Corporation did not have evidence of a suspension and debarment check. Views of Responsible Officials: Management agrees with the finding and has prepared a corrective action plan. Description of Corrective Action Plan: Management will review procurements done by the food service management company. Management will also ensure that appropriate procurement processes are followed for all future purchases and suspension and debarment checks are completed for purchases over $25,000. Responsible Party and Timeline for Completion: The Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) INDIANA STATE BOARD OF ACCOUNTS 36 Lakeland School Corporation 0825 E 075 N, LaGrange IN 46761 Phone: (260) 499 - 2400 Fax: (260) 463 - 4800 ______________________________________________________________________________________________ Educating and preparing ALL students for career & life success! Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5- 22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: The projected date of completion is March 31, 2026.

FINDING 2025-004 CNC Procurement and Suspension and Debarment Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Accounting Department will start keeping a binder that will include all the Procurement and Suspension and Debarment Certificates pertaining to the vendors in our federal programs, which includes Child Nutrition, that equal or exceed $25,000 for each school year. The A/P Clerk will alert the Treasurer when a certificate is needed, and the Treasurer will first check SAM, and then proceed with collecting a certificate from the vendor if one is not found online. When applicable, we can add a clause or condition to a contract noting this acknowledgement. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures for sole source or limited source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Implementation date: May 31, 2026 Responsible person: Yolanda Davis, Deputy Director, Financial Administration Division

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 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 compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

We will be updating our internal procurement policy. We will also review our policy and train staff on it annually as well as with new hires during orientation to ensure that the policy is understood and followed.

Finding 2025-004 Internal Controls Over Procurement Condition: Northern Illinois University (University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University implemented revised procedures and targeted training beginning in April 2025 to strengthen compliance with 2 CFR 200 procurement requirements. The transactions identified in the condition occurred prior to full implementation of this corrective action. 2. The University will continue to monitor procurement processes to ensure accurate and complete documentation of the procurement method selected. Individual(s) Responsible for Corrective Action: Sponsored Programs & Procurement Services & Contract Management Staff Anticipated Completion Date: June 30, 2026

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Corrective Action Plan: DNR will enhance subrecipient monitoring procedures to specifically include documented reviews of subrecipient procurement policies and procurement files to ensure compliance with applicable federal requirements and the subrecipient’s own written policies. DNR will revise subaward templates and procedures to ensure that all required federal award information and applicable terms and conditions, including closeout requirements, are consistently included in subaward agreements at the time of issuance. DNR will develop and implement formal written procedures for subrecipient Single Audit monitoring. DHHS will continue to improve subrecipient monitoring where necessary. NDCS will revise its policy to include a requirement for verifying subrecipient qualifications for federal funds. Additionally, NDCS will notify all subrecipients that proper payroll and benefit documentation must be submitted to ensure accurate cost allocation. NDCS will ensure that all required subaward documentation is provided to each subrecipient. This documentation will include: a. The subrecipient’s Unique Entity Identifier (UEI) b. Federal Award Identification Number (FAIN) c. Federal Award Date d. Federal award project description e. The name of the Federal agency, pass-through entity, and contact information for the awarding official of the pass-through entity f. Assistance Listings title and number g. A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements h. Appropriate terms and conditions concerning closeout NDCS will incorporate these requirements into its subaward process to ensure compliance with federal regulations. Contact: Erv Portis, Shelby Mikulak, Heather Arnold, Jenise Trautman Anticipated Completion Date: June 30, 2026

Procurement Finding 2025-003 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Corrective Action Plan: Catholic Charities is enhancing procurement oversight and compliance by centralizing procurement documentation, strengthening review and approval controls, and increasing management oversight. Procurement records will be centrally maintained and made accessible to the Accounting and Compliance Departments, in order to support monitoring and audit readiness. Updated training and standardized compliance tools are in the process of implementation, to reinforce consistent application of federal procurement requirements. In addition, Catholic Charities is strengthening vendor oversight through a centralized vendor management process that ensures ongoing monitoring for suspension and debarment. The Compliance Department already runs regular debarment/suspension checks against all vendors engaged in any form of agreement (e.g., contract, grant, MOU, amendment, etc.) but has no visibility to vendors not tied to an agreement. To solve this, the Compliance Department will request a report from the Accounting Department, which lists all vendors paid and will run debarment and suspension checks. All new vendors will be reviewed prior to engagement, and existing vendors will be reviewed on a recurring basis using this report. Responsible Individuals: Primary: Carys Church, Procurement Manager Secondary: Elizabeth Knight, Chief Compliance Officer; Mary Ammer, Sr. Director of Accounting and Finance Anticipated Completion Date: April 2026

FINDING 2025-005 Finding Subject: Special Education – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Dr. Wendy Skibinski Contact Phone Number and Email Address: 317-205-3332 x 77230 wskibinski@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Special Education will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Annette Guenther Contact Phone Number and Email Address: 317-205-3332 x 77209 aguenther@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Child Nutrition will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

February 26, 2026 Federal Awards Finding 2025-001: Child Nutrition Cluster (CFDA 10.553, 10.555) Compliance Requirement - Procurement Condition – The School District made purchases charged to the Child Nutrition Program in excess of $20,000 without obtaining competitive bids as required by the School District’s procurement policy. Corrective Action Plan – The school lunch manager will monitor expenses for the Child Nutrition Program to ensure no purchases will be made in excess of $20,000 that have not been competitively bid for the 2025-2026 school year. For the 2026-2027 school year, the school lunch manager will competitively bid the products for all vendors that may exceed $20,000 for the school year. Responsible School District Official – Emily M. Sanders, School Business Administrator Completion Date – July 1, 2026

The County's current procedure requires documented acknowledgement that the vendor was verfied to not be suspended, debarred, or otherwise excluded prior to entering covered transactions. Effective February 25, 2026, the County's procedure will require documented verfication that vendors are not suspended, debarred, or otherwise excluded prior to entering into covered transactions and retain such documnetation within the procurement file, in accordance with CFR 200.212 and 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6.

Finding Summary: During the course of the engagement, Eide Bailly identified that the District’s procurement policy was not fully in compliance with all of the Uniform Guidance standards. Responsible Individuals: Rhandi Knutson, Director Corrective Action Plan: A procurement policy that is fully in compliance with Uniform Guidance will be approved and implemented. Anticipated Completion Date: June 30, 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: To address this repeat finding, the Business Manager will now review all federal purchase requests before any funds are committed. We will ensure the correct procurement method is used by requiring and filing at least three competitive quotes for any small purchase between $10,000 and $150,000. For any transaction $25,000 or greater, the Business Manager will verify the vendor’s eligibility on SAM.gov and keep a date-stamped screenshot in the file as proof of the search. This centralized oversight and mandatory documentation process will ensure we maintain a proper history of procurement and prevent further noncompliance. Anticipated Completion Date: 02/01/2026

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering a covered transaction. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through NEISEC we will need to take action to secure bids and quotes and keep copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on NEISEC to check on suspension and debarment Anticipated Completion Date: Immediately

#2025-001 Lack of Required Independent Estimate for Procurement Exceeding the Simplified Acquisition Threshold 1. Update Policies and Procedure Management will revise procurement policies and procedures to clearly require: preparation of an independent estimate, and completion and documentation of an independent estimate for all procurements exceeding the simplified acquisition threshold. 2. Implement Procurement Control Checkpoints System-based controls and/or manual review checkpoints will be added to ensure independent estimates are attached before purchase orders or contract awards are approved. 3. Staff Training Procurement and program staff will receive training on: federal procurement requirements (2 CFR 200), when independent estimates are required, and how to properly prepare and retain the documentation. 4. Ongoing Monitoring and Compliance Review Management will implement periodic reviews of procurement files to verify compliance with updated policies. Any deficiencies noted will be corrected promptly and used to inform additional training needs. Responsible Party: Business Manager Timing for Completion: Within 90 days

Finding Reference Number: Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement – Child Nutrition Cluster Corrective Action: The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the procurements. The District will assign someone in the District office to review procurement requirements and ensure contracts meet the District’s policies. The Business Manager will work with the Food Service Director on a process to review procurement requirements and to ensure the contracts meet the District’s policies. This will include language to ensure that a person in the business office will review purchases submitted by the food service department to ensure they are meeting policy requirements. Responsible Person: Shannon Grindell, Susan Mayer

Finding 2025-006 – Procurement and Suspension and Debarment Contact Person: Michael R. Castilleja, Director of Procurement and Other Support Services Current status: In-Progress Anticipated Completion Date: March 1, 2026 Condition: The University did not maintain records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Identification of repeat finding: Yes – 2024-004; 2023-004 Resolution: UIW is committed to complying with 2 CFR 200.303 which requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The University will document the methodology used to select sole source or preferred vendor procurements through completion of the Sole Source/Preferred Vendor Justification Form. This documentation must include a clear and detailed rationale for vendor selection, an explanation of why competitive procurement was not feasible or appropriate, and a summary of any meetings, evaluations, market research, or review processes conducted prior to the final selection. A standardized Sole Source Justification Form is currently in place and will continue to be used in accordance with University policy. For procurements exceeding the micro-purchase threshold, completion and approval of the Sole Source/Preferred Vendor Justification Form is required prior to purchase. The required approval levels are based on procurement dollar thresholds. These approval levels will align with applicable federal, state, and institutional compliance requirements as listed in the University policy. All Sole Source/Preferred Vendor requests should be reviewed/signed by the requestor, Dean/Director and the Director of Procurement. The Grants Office and Procurement Office are responsible for reviewing and verifying all required documentation prior to purchase approval to ensure compliance with funding requirements and applicable regulations. The UIW Procurement Department conducts quarterly training sessions for the campus community. These sessions will include reinforcement of requirements and expectations related to sole source and preferred vendor procurement to promote consistent compliance and proper documentation practices.

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Guidance. Procurement policy should include general procurement standards as described by the Uniform Guidance, that include standards on conduct covering conflicts of interest; method of procurement for micro-purchases, small purchases, sealed bids, and proposals; and all other criteria as outlined in 2CFR 200.318 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a procurement policy that is in compliance with the Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Sydney Falk, CFO Planned completion date for corrective action plan: February 28, 2026

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding from the previous fiscal year 2024-001 CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the District adheres to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance.MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. The implementation of this procedure took place after the questioned cost noted this fiscal year and will be effective for all future District procurements.