Corrective Action Plans

2025-003 – Lack of Written Findings and Questioned Costs. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Ross Wilson, Village Clerk/Treasurer. Anticipated Completion Date: February 2026.

Health Center Program Cluster – Assistance Listing No. 93.224/93.527 Recommendation: The auditor recommends management implement suspension and debarment verification process for all covered vendors, regardless of their history or reputation, to ensure compliance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the recommendation: Management agrees with the finding and acknowledges that timely suspension and debarment verification was not consistently performed across all vendors. To address this deficiency, the Agency is implementing a standardized process to ensure suspension and debarment checks are conducted prior to entering into any covered transaction, regardless of vendor history. This process will include documented verification steps, annual review protocols, and staff training to reinforce compliance with federal procurement regulations. Name(s) of the contact person(s) responsible for corrective action: Chuck Walzel, CPA, Senior Vice President & Chief Financial Officer, 210-334-3724 (office) Planned completion date for corrective action plan: August 31, 2025

FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Corrective Action Plan: We will create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200. Proposed Completion Date: March 31, 2026

Finding 2025-003 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Procurement Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The entity has not established or documented a formal procurement policy or procedures to guide the acquisition of goods and services. No written guidelines were provided during the review period. Management Response: Management intends to establish a procurement policy. Status: In progress Anticipated Completion Date: Estimated 2025

The Capital District YMCA will develop and implement a written procurement policy in accordance with 2 CFR Section 200.318 and have it in place by July 31, 2025. The SVP/CFO Mary Maziejka will be responsible for development and implementation of the policy.

View of Responsible Officials: ICMEC is currently updating our written policies and procedures to ensure that the hiring and procurement process for contractors is properly conducted, reviewed, approved, and documented. In addition, ICMEC now requires a Procurement Memo to be prepared for each new contractor hired, outlining the procurement method, the hiring team, the selection process, the due diligence steps taken, and the contract details. These memos are prepared by the hiring supervisor or responsible Human Resources manager, reviewed by the organization’s General Counsel, and approved by the CEO.

Department of the Treasury Federal Financial Assistance Listing/ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: The Organization does not have a procurement policy that conforms to applicable standards under Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth in the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement policies required. Responsible Individuals: Steve Kuehneman, Executive Director, Bob Pawlikowski, Director of Finance and the Board of Directors of CARE Communities. Corrective Action Plan: Management agrees with the finding. Management and the Board of Directors have reviewed Eide Bailly’s procurement recommendations and will adopt a Board-approved Procurement Policy that complies with Uniform Guidance. The Organization will apply these procurement requirements to all applicable contracts and will review contracts to ensure inclusion of all provisions required under Uniform Guidance. Anticipated Completion Date: 2026

Finding Number: 2024-004 Finding Title: Procurement and Suspension and Debarment Program: 20.205 Highway Planning and Construction Name of Contact Person Responsible for Corrective Action: Jennifer Luhmann & April Wellman Corrective Action Planned: Faribault County Public Works will ensure all fiscally sponsored project files contain required documentation as stated in U.S. Code of Federal Regulations 200.318(i) and 180.300. Anticipated Completion Date: December 31, 2025

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

Finding 2024-001: Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Condition: During our testing of procurement for ALN 21.027, we noted that the City procured certain goods/services through the Commonwealth of Pennsylvania’s COSTARS cooperative purchasing program. For items selected for testing, totaling $184,512, the City did not conduct its own competitive procurement process. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. The City does not have implemented monitoring procedures over its use of COSTARS, including [e.g., periodic review of COSTARS procurement documentation, confirmation that COSTARS contracts were competitively awarded, and verification that applicable federal clauses are incorporated]. Documentation in the procurement files was not sufficient to clearly demonstrate how the underlying COSTARS procurement complied with the Uniform Guidance procurement standards for the specific federal award (e.g., basis for contractor selection, method of procurement relative to 2 CFR 200.320 thresholds, and required federal contract provisions). Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the value of the procurement transaction. Cooperative purchasing arrangements (such as state contracts or COSTARS) are not prohibited by the Uniform Guidance; however, the municipality must assume responsibility for the procurement and document how the cooperative contract satisfies the federal procurement requirements applicable to the award. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. The City has chosen to leverage the COSTARS cooperative purchasing program to improve efficiency and obtain favorable pricing. While the City has implemented monitoring over COSTARS (for example, reviewing selected COSTARS contract information and maintaining communication with the state regarding procurement practices), those procedures have not been formalized in the written procurement policy, and the related documentation is not consistently retained in the individual grant procurement files. As a result, the audit file did not contain clear, consistent evidence that the COSTARS contracts used for the tested transactions met all applicable Uniform Guidance procurement requirements. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. In addition, without documentation demonstrating clear, consistent evidence that COSTARS contracts used for purchases met all applicable Uniform Guidance procurement requirements, there is an increased risk of noncompliance which could result in unallowable costs being charged to the Federal awards. Repeat finding: Yes, finding 2023-002 Questioned costs known and likely: $184,512 known and $124,662 likely. Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows all Uniform Guidance procurement standards, especially regarding cooperating purchasing programs. View of Responsible Officials and Corrective Action Plan: Management agrees with this finding. Although procedures were previously established to ensure compliance with Uniform Guidance procurement standards, the finding recurred due to inconsistent implementation and insufficient monitoring of those procedures, particularly related to the use and documentation of cooperative purchasing programs.

Finding 2024-003: Significant Deficiency and Noncompliance over Procurement, Suspension, and Debarment Responsible Official’s Response and Corrective Action Plan We concur with the finding. The Foundation has an informal process of reviewing vendors and determining if they have been suspended or debarred. However, there is not a formal process where proper documentation such as screenshots of the search are saved. Due to the transition in the accounting department, we were not aware of these specific criteria at the time. We were notified of these requirements after the end of fiscal year 2024. To address these issues, a comprehensive process was implemented during fiscal year 2025 to ensure proper documentation and compliance with procurement regulations. This process will include: 1. Ensuring that all sole source vendor selections are properly documented and justified. 2. Verifying and maintaining records that confirm vendors are not debarred or suspended from doing business with the Federal Government before entering into contractual agreements. We are committed to improving our procedures and ensuring compliance with all applicable regulations moving forward. Planned Implementation Date of Corrective Action Plan June 2025 Person Responsible for Corrective Action Plan Natésha Johnson, Director of Finance and Administration Dr. Felecia Nave, President and Chief Executive Officer Luwanda Jenkins, Vice President of Partnerships and External Relation

Finding 2024-005 – Inadequate Procurement Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the InteriorFederal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Federal procurement standards require non-Federal entities to maintain records sufficient to detail the history of procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. Competitive procurement must follow the entity’s written procedures consistent with 2 CFR §§200.317-200.327, including:  Written procedures for procurement (§200.318(a)).  Full and open competition requirements (§200.319).  Methods of procurement (sealed bids, proposal requirements, and required documentation (§200.320).  Contract cost and price justification, (§200.324).  Suspension/debarment verification for covered transactions (§200.214; §200.213). Condition: During the audit period, the Entity did not retain sufficient procurement documentation for several contracts funded under the above Assistance Listings. Specifically, files lacked one or more of the following:  Evidence of the procurement method used.  Price or cost analysis.  Suspension/debarment checks for vendors where required.  Documentation of competition.  Conflict-of-interest attestations. Cause: Partnership for the Umpqua Rivers procurement procedures were not sufficiently detailed or consistently applied to federal purchases. No evidence of procedures or review for procurement or suspension / debarment was provided to auditors. Turnover and limited training on Uniform Guidance procurement standards contributed to the inconsistent file completeness. Effect or Potential Effect: Without complete procurement documentation, the Entity cannot demonstrate compliance with federal procurement requirements, increasing the risk of:  Noncompetitive awards or unreasonable prices.  Unallowable costs for the award requirements.  Potential disallowance or repayment of federal funds.  Findings in federal or pass-through monitoring and future audits. Questioned Cost: Yes, $902,496 related to expenditures that had no procurement support or detail. Context: During our audit, it was found that the Partnership for the Umpqua Rivers had experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to procurement, suspension or debarment procedures or processes. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Update Written Procurement Procedures o Incorporate Uniform Guidance thresholds and methods (§200.320), competition requirements (§200.319), and documentation expectations (history of procurement). o Embed steps for suspension / debarment checks and Appendix II Contract clauses.  Standardized Procurement Checklist o Pre-award checklist that verifies: method, competition evidence, cost/price analysis, conflict of interest attestations, SAM exclusion check, and required federal clauses. o Post -award checklist ensuring complete contract file (award memo, bid tab / evaluation, signed agreement, clause verification).  Cost/Price Analysis Guidance o Require documented price reasonableness for small purchases, formal cost or price analysis for larger or sole-source awards, per (§200.324).  Training & Accountability o Provide targeted training to procurement and program staff on 2 CFR §§200.317- 20.327 and Assistance Listing award conditions. o Implement supervisory pre-award review and periodic file audits. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a forma', written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file checklist before a contract is executed. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand H U D's procurement standards, including requirements forf ull and open competition and proper record-keeping. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto, COO, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by May 1, 2026.

2024-004 Procurement, Suspension and Debarment The Committee acknowledges that certain procurement procedures were not followed, leading to a finding of noncompliance. To remedy this, on July 1, 2025 we put new workflow controls in place within our new integrated accounting software. These workflows support compliance with our procurement policies and ensure all required supporting documentation, including forms for micro and small purchases, are secured and archived for capital purchases and grant expenditures. This will ensure that all procurement policies, which are in compliance with all FTA guidelines, are consistently followed.

FINDING 2024-002 – PROCUREMENT PROCEDURES-AMERICAN RESCUE PLAN (ARP) ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND (ESSER III) - ALN 84.425U-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 ‘Associates in Counseling’. This is a repeat finding 2023-002 from the prior fiscal year.-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, that the District adhere 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.-District Officials Responsible for the Implementation of the Corrective Action Plan:-Aubrie Schnelle, Superintendent, and Austin Blauser, Business Manager

FINDING 2024-010 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement - Small Purchases The school corporation will follow all Federal Requirements for small purchase procedures including obtaining price or rate quotations from an adequate number of qualified sources. We will document the procurement method we are using and attach supporting documentation for rate and price quotes by source. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, the school corporation will verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. All purchases $25,000 or greater will involve the following process - (1) checking SAM.gov to see if there are any exclusions, (2) require Vendor supply certification that they have not been suspended or debarred OR clause will be added to agreement or contract signed by Vendor as certification. Anticipated Completion Date: December 1, 2025

SPECIAL EDUCATION CLUSTER – PROCUREMENT U.S. Department of Education Special Education Cluster Assistance Listing Number: 84.027 & 84.173 Passed Through Minnesota Department of Education Pass Through Number: H027A220087 Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025 and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – PROCUREMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 93.600 and 93.558 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Views of Auditee and Corrective Actions: GDOE disagrees with the finding. GDOE does allow for vendors to provide quotes for brand name or equal products. In this case, the substitute product offered was not equal to the product GDOE was soliciting. The end user provided justification that the substitute product did not meet the needs or specifications requested.

Views of Auditee and Corrective Actions: GDOE disagrees with the finding. Auditors cited the lack of procurement policies that meet 2 CFR 200.324(a), but did not find any evidence that GDOE did not comply with procurement regulations.

VFC is in the process of updating its entire accounting policies and procedures manual, which includes the procurement policy. This policy will be written to comply with all federal and state statutes and regulations. The expected completion date is December 31, 2025.

Finding Title: Noncompliance with Procurement Standards – Professional Services Responsible Person: Grace Kim, CFO Corrective Action Plan: The Foundation acknowledges the auditor’s finding that procurement standards were not followed when the attorney for this project was hired. Management did not anticipate the need to apply procurement requirements to legal services at the time of engagement. Management recognizes the importance of procurement regulations as a core internal control responsibility and will implement the following corrective actions: The organization will formalize and strengthen its procurement procedures to ensure compliance with applicable requirements. Specifically: 1. A written procurement policy will be developed and adopted that clearly defines competitive quote and documentation requirements for all goods and services, including professional services such as legal counsel. 2. The policy will specify thresholds requiring multiple price quotes or justification for sole-source procurement. 3. Management will require documentation on price comparisons or written justification prior to executing contracts or engagement letters for professional services. 4. Staff involved in procurement and contract approvals will be trained on the new procurement policy and compliance requirements. Anticipated Completion Date: January 1, 2026

Conditions – During 2024, the Organization did not maintain documentation related to how they chose a contractor for construction projects such as how they chose contractors to get bids from, how many bids were obtained, detailed bid information, and what factors they considered in choosing a contractor. No documentation exists showing considerations of price, contingencies, length of contract, and perceived risks. Recommendation – We recommend maintaining documentation supporting the compliance with federal regulations for all expenditures of federal funds. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the finding and appreciates the auditor’s recommendation. The Organization exceeded the Single Audit threshold for the first time in 2024 due to a one-time coronavirus-related grant. As a result, management was not fully aware of the federal procurement documentation requirements applicable to these funds. To address this matter, management has implemented procedures to ensure that procurement documentation supporting compliance with federal regulations is maintained for all federal expenditures. These procedures include staff training on federal grant compliance requirements, enhanced oversight of procurement activities, and the use of standardized documentation and retention practices. Management believes these corrective actions will mitigate the risk of future noncompliance and strengthen overall federal grant administration.

Conditions – During 2024, the Organization did not have a written procurement policy. Recommendation – We recommend that the Organization develop and implement a written procurement policy. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the finding and appreciates the auditor’s recommendation. The Organization exceeded the Single Audit threshold for the first time in 2024 due to a one-time coronavirus-related grant. As a result, management was not fully aware of the federal procurement documentation requirements applicable to these funds. To address this matter, management has implemented procedures to ensure that procurement documentation supporting compliance with federal regulations is maintained for all federal expenditures. These procedures include staff training on federal grant compliance requirements, enhanced oversight of procurement activities, and the use of standardized documentation and retention practices. Management believes these corrective actions will mitigate the risk of future noncompliance and strengthen overall federal grant administration.

Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all department heads to ensure proper compliance in the utilization and disbursement of federal funds.