Corrective Action Plans

Finding 2025-003: Procurement, Suspension and Debarment The single audit report included the following recommendation: EY recommends that Amtrak include legal expenses within their procurement, suspension and debarment policy as outlined within each of the grant agreements. Management Response/Status of Action Plans: Pursuant to Section 26(j) of Amtrak’s annual grants, Amtrak’s policy is to fund most law firm engagements with Program Income without applying grant requirements that apply to other procurements. In FY2025, this was the case for all law firm engagements charged to operating activities. Also, in FY2025, Amtrak had a portion of its legal expenditures charged to capital projects based on the nature of the legal work performed. These capital projects were funded with federal grants. For legal expenditures which are by their nature related to projects funded by grants, Amtrak acknowledges the need to have the proper procurement process including competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-down based on the grants. By the end of FY2026, the Law Department will review and update its internal procedures to better prevent recurrence of legal expenditures that did not have proper competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-downs from being charged to projects funded by grants. As part of that review, Amtrak will consider whether it may be appropriate to utilize the Company’s broader procurement policies. The contacts for this item are Lucia Butts, AVP Funding and Grants and Thomas Bloom, Deputy General Counsel and Corporate Secretary. Amtrak anticipates fully remediating this finding by September 2026.

A procurement checklist will be developed to require proper documentation if utilizing Federal Funds. The checklist will list specific thresholds for procurement based on funding type, and whether the procurement is construction related and list requirements and thresholds for the construction activity. A new vendor checklist will also be developed to ensure that the vendor is not debarred and/or suspended prior to conducting business with them. The checklist will also list other relevant documents that will be needed prior to first payment. The anticipated completion date will be 9/30/2026.

Federal Procurement Regulations Planned Corrective Action: During the audit period, HAH experienced significant organizational transition, including separation from its parent organization, turnover in key administrative and finance positions, and the rebuilding of internal financial operations and controls. These circumstances contributed to inconsistent application and documentation of procurement procedures. To address this deficiency and prevent recurrence, HAH worked with HRSA Technical Assistance resources to develop an enhanced procurement policy and procedure, which is scheduled for Board approval in May 2026. In the interim, HAH has reinforced procurement requirements through staff training and communication regarding federal procurement standards. Additionally,management has implemented ongoing monitoring and compliance reviews of procurement activities to ensure adherence to policy requirements, including appropriate bid documentation and sole source justification when applicable Person Responsible for Corrective Action Plan: Donald McGruder, CFO Anticipated Date of Completion: Resolved

Finding 2025-001 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters 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 and Context: During our testing as it related to compliance with procurement we noted that an expense for engineering services for the Waste Water Treatment Assessment services charged to the major program would have required a formal bidding process as the project exceeded the simplified acquisition threshold. The Town had selected the engineering company for “On Call” engineering services as it related to the DPW through a request for qualifications process. The contract does include as part of the services to be provided Waste Water Treatment Assessment services. However, the contract is not specific to federally funded projects. The Town of Medfield had submitted the request for qualifications documentation as well as the executed contracted for “On Call” services to both the Town’s consulting service and the pass through entity for approval of the Waste Water Treatment Assessment. The pass through entity and the pass through entities Auditors did not have any concerns with the request for qualifications as it relates to the Waste Water Treatment Assessment project. Questioned Costs: $175,500 Cause: Based on the judgement of the pass through entity (Norfolk County) and their auditors, the Town was approved to procure engineering services for the Waste Water Treatment Assessment as part of a larger “On Call” services contract. The Town did select the contractor through a competitive request for qualifications process, but did not initiate a separate procurement for the sub-project. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2024-001 Recommendation: Going forward, the Town of Medfield should consider a separate bidding process for expenses related to federal grant funds. Responsible for Corrective Plan: Contact Person: Kristine Trierweiler, Town Administrator Estimated Completion Date: May 7th, 2026 Action Taken: On an ongoing basis, the Town will initiate separate procurements for projects covered under federal grants.

This is the result of procurement transactions fonded with the ARPA Coronavirus State and Local Recovery Funds. The County did not conduct procurement transactions in a manner providing fair and open competition on two constrnction contracts. The comptrollers office will enhance procurement policies and review of federal grant funded purchases.

Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding Lincoln Public Schools procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management will update Lincoln Public Schools’ procurement policies to include all essential elements to be in compliance with Uniform Guidance.

East Rio Hondo Water Supply Corporation will implement procedures to verify vendor eligibility through SAM.gov prior to awarding contracts or processing payments related to federally funded projects. Documentation of the verification will be maintained with the related disbursement or procurement records. Responsibility for performing and documenting the verificaiton process will be assigned to accounting personnel and reviewed by management. Implementation of these procedures will begin in 2026.

Management will improve procurement compliance controls by: • The verification and retention of support that vendors are not suspended or debarred has been moved to be part of the accounts payable onboarding process of vendors and maintained in the vendor’s file in the accounting system. • Implementing a standardized checklist or form documenting that the verification that a vendor has not been suspended or debarred prior to contract execution and/or payment. • Providing refresher training to staff involved in procurement and accounts payable on documentation requirements.

The District is in the process of updating the Federal Procurement Procedures with the new thresholds that were issued in September. The District will get quotes for all items purchased with Federal funding in the future to avoid future findings. New Philadelphia City School District makes every effort to procure items based on the policies and procedures in place. We also follow the Uniform Guidance to the best of our ability.

Actionable plan: The Organization adopted a written, standalone procurement policy to govern transactions under Federal awards. This policy will be designed to strictly comply with the procurement requirements outlined in the Code of Federal Regulations, specifically 2 CFR 200.318. Responsible individual: Madeline Henriquez, Executive Director, and the Board of Directors Completion date: February 17, 2026

Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with Build America, Buy America (BABA) Act. Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grantrequired stipulations such as BABA requirements, monitoring, compliance, and documentation. Anticipated completion date: We will develop and approve the updated procurement policy by 7/31/2026.

The Town of Spruce Pine will update its written procurement policies to fully incorporate current federal procurement standards under 2 CFR §§200.317–200.327 and applicable state procurement regulations. Management will provide training to staff involved in procurement and contract administration. The Town will also establish an annual policy review process to ensure procurement procedures remain current and compliant.

Corrective Action Plans Finding 2025-001 – Noncompliant procurement policy Corrective Action Plan: The Village will update its written procurement policy to comply with applicable State, local, and tribal laws and regulations and with Federal requirements under 2 CFR §200.317–200.326. In addition, the Village will train personnel on the updated policy. This policy will apply to all purchases of goods, services, and construction funded in whole or in part by Federal awards administered by Village of Hazel Crest, including subrecipients and contractors, unless superseded by more restrictive State, local, or tribal law. Person(s) Responsible: Amanda Page-Horvet, Accounting Supervisor Timing for Implementation: Fiscal Year 2027

Finding: 2025-002 Federal Agency Name: U.S. Department of Treasury Assistance Listing Number(s): 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Finding Summary: 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. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the Non-Federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. It was noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Responsible Individuals: Kyle Wilmot, Canyon County Controller. Corrective Action Plan: Members of the audit office will review each vendor in the SAM.gov database to ensure that they are not suspended, debarred or otherwise excluded. The search of these entity(s) will then be saved to the shared drive for the upcoming ACFR season and the supervisor will be notified of the search to ensure that the files have been properly saved. Anticipated Completion Date: Canyon County will complete the corrective actions for the September 30, 2026, reporting period.

Single Audit Finding No. 2025-066 - Contractor certified payrolls for four of 11 construction projects tested were not submitted during FY25. Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with this finding and recommendation. Corrective Action (corrective action planned): The department will implement measures to follow up with contractors and document attempts to contact businesses. Management will provide additional staff training regarding processes and procedures to ensure that the department is following up with due diligence. Completion Date (list anticipated completion date): December 31, 2026 Agency Contact (name of person responsible for corrective action): Michael White, Financial Services Manager

Suspension and Debarment – Assistance Listing No. 14.267 Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will update procurement procedures to require documented SAM.gov verification for all new vendors prior to contract execution and periodically for existing vendors. Evidence of verification (e.g., screenshots or confirmation reports) will be retained in procurement files. Management will also evaluate engaging a third‑party service to perform monthly suspension and debarment screenings. Compliance will be reviewed as part of routine procurement oversight. Name(s) of the contact person(s) responsible for corrective action: Scott Russell Planned completion date for corrective action plan: 6/30/2026

The University will strengthen procurement policies and procedures to ensure full compliance with federal requirements, including clear guidelines for sole-source justifications and competitive procurement thresholds. A standardized procurement documentation checklist will be implemented to ensure all purchases include required support, such as quotes, cost analysis, and written justification for noncompetitive procurements. Pre-procurement review and approval controls will be established to verify compliance prior to vendor selection. The University will enhance oversight and monitoring of procurement activities, including periodic internal reviews, and provide training to staff on federal procurement standards. All procurement records will be maintained in a centralized and organized system to ensure a complete audit trail. Corrective measures will be implemented within 30–60 days with ongoing monitoring.

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

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

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

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

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

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

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