Corrective Action Plans

Management’s Response/Corrective Action Plan (Unaudited): Management acknowledges the finding. For the transaction tested, the original contract was approved in 2021, and we initially intended to use the general fund as a source of payment. The City has reviewed and updated its procedures to require that documentation behind the analysis of the type of procurement steps be saved in the contract file. Staff will be retrained on these requirements to ensure documentation is consistently maintained for all covered transactions in accordance with federal guidelines. Planned Completion Date: These modifications are being implemented immediately. Contact Person Responsible for Correction Action: Finance Director

The County is aware that its policy on procurement was not followed in this situation and has taken steps to correct the situation for future purchases related to this program.

Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: Mandatory documentation of quotes for applicable procurements Verification and documentation of suspension and debarment checks for all covered transactions Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement Contact Person Responsible for Corrective Action: David M. Kennard Contact Phone Number and Email Address: 812-677-3959 clerk@princetoncity.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will establish a proper system of internal controls to ensure expenditures made from federal awards use the appropriate procurement method and retain the documentation to support the procurement methods used in order to ensure compliance with the terms and conditions of the federal awards. Anticipated Completion Date: The corrective action plan will go into effect immediately.

Management acknowledges the oversight and agrees with the recommendation to strengthen procurement documentation controls. At the time, FAFCU utilized a third-party vendor management service, CUVM, to perform vendor verification and ensure that all vendors were adequately reviewed. However, following the merger and given that more than 15 months have passed since, the current Credit Union no longer maintains documentation from CUVM, as CUVM is not a vendor of the merged institution. While no improper expenditures were identified, CU1 recognizes the importance of maintaining evidence of suspension and debarment checks when federal funds are used. This finding relates to expenditures incurred prior to the merger, and following the merger, the current Credit Union is no longer a member of the CDFI Fund. Accordingly, the procurement requirements under CDFI ERP and Uniform Guidance no longer apply. To address the finding, CU1 has: • Documented the procurement oversight issue as part of merger due diligence. • Confirmed that no questioned costs were identified and no further vendor payments will be made under the CDFI ERP program. As CDFI Fund membership and federal procurement requirements no longer apply post-merger, no additional corrective actions are necessary. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

Isler recommended LCOG establish and implement formal, documented procedures for verifying that vendors are not suspended or debarred before entering into covered transactions paid with federal funds. These procedures should specify the method of verification (e.g., checking SAM.gov) and require retention of evidence (e.g., dated printouts or screenshots of the search results) within the procurement or vendor files. This has already been implemented as part of the procurement process.

Condition: The Organization did not have controls to retain documentation that the procurement process was followed to ensure more than one vendor was reviewed for pricing before selecting the vendor chosen (as required under 2 CFR 320(a)(2)(i)). Planned Corrective Action: Management will implement controls to ensure proper support of the procurement process is retained. Contact person responsible for corrective action: Manas Mehandru, COO Anticipated Completion Date: December 31, 2025

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.

2024-001 – Internal Controls over Compliance and Compliance with Procurement Standards Individual Responsible for Corrective Action Plan: Meghan Davies, Chief Operating Officer Anticipated Completion Date: Effective immediately Corrective Action Plan: WWH’s Chief Operating Officer will be the single point person responsible for ensuring all federally funded procurements are managed properly and that all documentation is maintained. In addition, an extra step will be taken to duplicate the filing system for all federally funded procurements into the grants management files themselves.

The YWCA has developed written procurement policy to comply with the federal requirements and revised existing procedures to maintain evidence that contractors and vendors are not suspended, debarred, or otherwise excluded from participating in federal programs.

Re: Management’s Response & Corrective Action Plan to Procurement Policy & Procurement Action Documentation (2024-004) The Wilmington Land Bank adopted a written Procurement Policy on September 11, 2024. At one property, however, the policy was not fully followed. The Land Bank initially considered the work a continuation of an existing project, but it was later determined that it should have been bid separately under the Procurement Policy. To strengthen compliance with the Procurement Policy going forward, the Land Bank will hold weekly internal staff meetings and weekly meetings with the City of Wilmington. These meetings will include a review of project updates and related procurement actions. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

2024-003 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not follow their documented procurement procedures for approving one contractor. Corrective Action Plan: All procurement procedures will be followed as documented in YWCA St. Joseph financial policies. Person(s) Responsible for Implementation: Danielle Brown, CEO, dbrown@ywcasj.org, 816-232-4481

RUMC follows applicable federal grant guidelines and requirements, including adherence to the three-bid policy and related procurement standards. However, there were two factors that impacted our ability to provide complete supporting documentation during the audit period: (1) the departure of the project manager who was responsible for maintaining procurement records for the project, and (2) a cyber event in 2023 that resulted in the loss of certain files and supporting documentation. While these circumstances limited our ability to produce documentation evidencing compliance, management affirms that the required procurement steps were performed and that RUMC remains in adherence with federal grant requirements. To further strengthen compliance, RUMC has established a Construction Grant Committee to ensure full adherence to all grant requirements. This committee is responsible for reviewing procurement actions, verifying compliance with the three-bid requirement, ensuring proper documentation is retained, and monitoring procurement processes throughout the life of each project. These corrective actions will ensure that complete and verifiable records

Finding 2024 002 – Activities Allowed or Unallowed and Allowable Costs/ Cost Principles, and Procurement Federal Agency: U.S. Department of Transportation Program Name (ALN): Public Transportation Emergency Relief Program (ALN 20.527) Federal Grant Numbers: NJ 44 X004 02 (Federal fiscal years 2012–2025) Contact Person: Fatima Castellanos, PATH, Finance & Business Planning Manager, 201-216-6459. Corrective Action: Although federal funds were not received for this expenditure, PATH acknowledges an internal control deficiency regarding the recognition of grant funding for work performed under standard nonfederal engineering call-in contracts. PATH will continue to work collaboratively with the Engineering and Procurement Departments to strengthen internal communications and reinforce adherence to established protocols governing capital projects that are eligible for federal funding. Procurement will provide and document targeted procurement training for awareness to Engineering and PATH staff on adhering to procurement protocols during the execution of contract work that is anticipated to receive federal funding. Anticipated Completion Date: Changes to the controls and processes will be implemented and training provided in the fourth quarter of 2025.

Finding # 2025-001 Type: Immaterial noncompliance U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing #11.441 Finding: The Organization’s fiscal policies and procedures do not meet the required federal standards for procurement set out at 2 CFR sections 200.318 through 200.327. The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Corrective Action: Management will work on revising the Organization’s procurement policies to incorporate the necessary provisions. Anticipated Completion Date December 2025

Going forward the Center will prepare and implement a procurement policy in accordance with Uniform Guidance requirements and ensure there is documentation that verifies vendors are not suppressed or debarred prior to entering into contracts with the vendors.

Giraffe Laugh will update the current procedural manaul to ensure that proper action is taken at the time invoices are submitted for approval. We anticipate having the procedure manual updated and ready by the end of the first quarter of the fiscal year 2026. Wihle proper protocols were being follwed, the manual was not adequately updated to reflect best practices. Anticipated completion date: March 31, 2026

Individual(s) Responsible: LaNita Perez, Controller and AP Specialist Action: Management will ensure that all procurement transactions comply with established policies and procedures. Competitive bidding, documentation of procurement methods, justification for sole-source contracts, and price/cost analyses will be required for all applicable purchases. Staff will receive training on procurement requirements under Uniform Guidance. Management will monitor procurement activities and verify that each purchase is supported by proper documentation. Compliance with policies and procedures will be checked regularly. Anticipated Completion Date: December 31, 2025

Adopting procurement policy that complies with UG procurement standards and distributed it to all staff with purchasing authority. The ED and Treasurer are currently developing a checklist that will be included as part of initiating contracts or purchases over the procurement threshold and that it is saved along with other grant documents. The bookkeeper will check the SAM data base for disbarment notices prior to queuing bills for amounts greater than $5,000 for payment

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Missouri Department of Transportation Audit Finding Number: 2024-015 - MoDOT Monitoring of BABA Provisions Name of the contact person responsible for corrective action: Todd Grosvenor, MoDOT Financial Services Director, 573-751-4626 Anticipated completion date for corrective action: January 12, 2026 Corrective action planned is as follows: MoDOT will develop written policies and procedures for monitoring contractor and subrecipient compliance with the Build America, Buy America (BABA) domestic preference provisions for Infrastructure Investments and Jobs Act (IIJA)-funded projects. To date, MoDOT has drafted the policies and procedures, which are being reviewed by the Federal Highway Administration (FHWA). The next available document submission date for policy revisions is November 27, 2025. MoDOT will submit the FHWA-approved monitoring plan to be added to MoDOT’s policies by that deadline. The policy is scheduled to be published by January 12, 2026. MoDOT will provide training to the department’s resident engineers in November 2025.

Corrective Action Plan for Finding 2024-01 Type of Finding: Internal Control and Compliance - Compliance and Material Weakness Deficiency over Procurement and Suspension and Debarment Federal Program: U.S. Department of Treasury, American Rescue Plan Act (ARPA) Federal Assistance Listing No.: 21.027 Condition: During the single audit, there was a finding of no documentation to support a competitive bidding or procurement process for certain vendor contracts, as required by federal procurement standards. Corrective Actions 1. Revise Internal Procurement Policy A. Action: The organization will revise its existing procurement policy to adhere with federal requirements for competitive bidding, including thresholds for different procurement methods (e.g., micro-purchases, small purchases, sealed bids, competitive proposals). The revised policy will clearly define the documentation required for each step of the procurement process. B. Responsible Party: Kimberly Royster (CFO) C. Anticipated Completion Date: October 15, 20252. Provide Mandatory Staff Training A. Action: The organization will train all employees, including those in finance, program management, and administration, on the new procurement policy and process. The training will emphasize the importance of compliance with federal regulations and the specific documentation requirements. B. Responsible Party: Wayne Lawson (HR) and Laura Connelly C. Anticipated Completion Date: November 12, 2025 3. Implement the Revised Procurement and Documentation System A. Action: The organization will implement the new procurement process for all procurement activities. This process will require documentation of all stages of the procurement process, from the initial request to the final contract award. This will ensure that a complete audit trail is maintained for every purchase. B. Responsible Party: Laura Connelly C. Anticipated Completion Date: November 12, 2025 4. Conduct Post-Implementation Monitoring A. Action: The organization will enlist the services of the external audit team to review the updated procedures. This will serve as a check to ensure the new policy meets federal requirements. B. Responsible Party: Current Auditor C. Anticipated Completion Date: December 31, 2025

The audit identified gaps in our procurement policies and procedures. In response, updated procurement policies have already been drafted. These policies align with federal requirements, strengthen internal controls, and establish clearer guidelines for competitive bidding, documentation and approval processes. The draft policies are currently under review by the Executive Director and will be finalized and implemented promptly.

Procurement, Suspension and Debarment Program: Program: ALN 66.458 Clean Water State Revolving Fund ALN 66.468 Drinking Water State Revolving Fund Condition: The City’s procurement procedures do not conform to Uniform Guidance requirements. Corrective Action Planned: The City will update procurement procedures to conform with Minnesota statutes and Uniform Guidance. Officer Responsible for Ensuring CAP: Goldie Smith, Clerk/Treasurer Planned Completion Date: 12/31/2025

Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026

Reporting - Reportable Findings and Questioned Costs for Federal Awards Contact Person Marc Taylor, CFO E-Mail: Marc@chiefseattleclub.org Corrective Action Planned This finding occurred because of a lack of both procurement knowledge and staff oversight over a contractor handling the procurement for Eagle Village. Thanks to this finding, our real estate team has gained a better understanding of federal procurement requirements. Our auditor provided us with a procurement checklist, which we began using and will ensure that we comply with our procurement policy and better document future procurements. Anticipated Completion Date September 30, 2025