Corrective Action Plans

As stated in the Management Letter issued by SAX regarding the Organizations procurement policy, 2024 was the first year the Organization received federal funding and therefore was not aware of the specific language required by the Uniform Guidance (2 CFR §200.317-.327) needed in the procurement policy. The Organization has worked with SAX to add policies to procurement policies to ensure that any future procurements required by federal funding received will include procedures required under the Uniform Guidance (2 CFR §200.317-.327).

FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends SFP perform suspension and debarment checks prior to entering into the covered transactions paid for with federal funding and to retain documentation evidencing that those checks were performed timely. Increased training may help reinforce the polices and requirements regarding suspension and debarment checks and documentation retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SFP will ensure that suspension and debarment checks are conducted and documented as per the applicable regulations. SFP will ensure all relevant staff receive updated training on procurement policies, including suspension and debarment checks. Name(s) of the contact person(s) responsible for corrective action: Annie Haylon Planned completion date for corrective action plan: October 31, 2025

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Additionally, Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025

Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipients of JAG funding are being included in NCS processes. Specifically, one position (Contract/Program Auditor) is assigned to each contract and is responsible for verifying and documenting suspension and debarment at award and at the annual renewal and also for ensuring monitoring is completed. Prior to the audit, NCS had begun scheduling with the subrecipient that had not been monitored, consistent with NCS processes. NCS is currently also developing a grant handbook to ensure that all staff are aware of general and specific grant requirements and processes for managing grants. Procurement. The City’s procurement policies and procedures outline the process for the competitive procurement of services using federal funds, in alignment with federal regulations. However, the City acknowledges that certain aspects of the current policies maybe unclear or inconsistence with existing procedures. Additionally, the City recognizes that its internal controls are not fully effective in ensuring that all departments consistently comply with these policies and procedures. To strengthen internal control, the City will revise its procedure and develop and implement training around federal grants for staff responsible for managing or overseeing these contracts.

Following the close of the 2023 audit in October 2024, 9/11 Day implemented a strengthened procurement process for all large vendors, including the adoption of a formal procurement policy that complies with federal guidelines. A vendor log and checklist system has been established to document the receipt of RFPs, the rationale and method of procurement, and decisions on whether to move forward with a vendor. Although 9/11 Day has, and does verify whether vendors and subgrantees are permitted to receive federal funds, we have now updated our policy to retain printed verification of each vendor’s/subgrantee’s eligibility to receive federal funds, including confirmation that these organizations are not suspended or debarred. These documents will be retained in the procurement file for each vendor/subgrantee. These steps ensure compliance with 2 CFR 200.318 and provide clear documentation and oversight for all procurement activities.

Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom pliant with federal procurement standards. Since the policy adoption, all new procurements have followed the updated procedures. The organization also did not keep records of debarment search results. • What's been done: All procurement following the adoption of the procurement policy has been done in alignment with the policy. We also introduced procurement "kickoff meetings" for new grants to review each budget line, determine the correct procurement method, and plan documentation for the procurement process. This has been piloted with our most recent grant. All vendors now have debarment searches in their QuickBooks vendor information tab. • Next steps: Apply this process to all new grants to ensure compliance from the outset. • Responsible party: Finance manager and Executive Director of Michigan Center for Adult College Success with oversight by President

The Organization will document a procurement policy to ensure it fully complies with the Uniform Guidance requirements.

Audit Finding Item 2024-001 Corrective Action Taken: In response to this finding, Tulsa Cares is developing and will formally adopt written procurement policies and procedures in alignment with the requirements outlined in 2 CFR 200.318(a). These policies will establish standards of conduct, ensure full and open competition, and provide clear guidance for the procurement of goods and services under federal awards. This corrective action will be completed by the next board meeting, scheduled for December 4, 2025. Responsible Party: Natalie Jarred, Chief Financial and Administrative Officer, is responsible for monitoring compliance with procurement policies and updating them as necessary.

FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Timothy Detrick – Clerk-Treasurer Contact Phone Number and Email Address: treasurer@townoffrankton.in.gov Views of Responsible Officials: Concur with the finding Description of Corrective Action Plan: I’ve already spoken with our Council President regarding the creation of an ordinance to establish a formal Procurement Policy, that mimics state law that’s already established. This ordinance will ensure that all new contracts entered into by the Town comply with Build America, Buy America (BABA) requirements. The ordinance will also ensure that the Town verifies both current and prospective vendors through the SAM.gov website to confirm their eligibility to receive federal funding. The ordinance will have in it that BABA must be follow and the town will verify that the contract is in good standing with the state but checking the SAM.gov website. Once check an affidavit will be made stating that that are in good standing, and signed by the council president and Clerk-Treasurer. Anticipated Completion Date: End of 2025 Date December 31st, 2025 INDIANA STATE

Finding 2024-003 AL No.: 66.468 Program Title: Drinking Water State Revolving Fund Federal Agency: U.S. Environmental Protection Agency Pass-Through Agency: Wisconsin Department of Natural Resources Award Number/Year: Unknown / 2024 Criteria: The Uniform Guidance requires in 2 CFR section 200.318(h) that entities receiving federal awards verify the suspension and debarment status of vendors before procurement takes place. Condition and Context: During testing, it was noted that the City did not document its review of suspension and debarment for both of the vendors tested for the federal program. Our sample was not statistically valid. Cause: The City did not complete and document the review of suspended and debarred vendors as required for expenditures of federal awards in accordance with the Uniform Guidance. Effect: If transactions occur with a suspended or debarred vendor, the funding agency may disallow the costs associated with the transaction. Questioned Costs: None noted. Recommendation: We recommend that the City complete and document the review for suspended and debarred vendors as required for expenditures of federal awards in accordance with Uniform Guidance before contracting with a vendor. Management's Response: The City did not perform a review for suspended and debarred vendors. Neither we, nor our engineering firm, had prior knowledge of this requirement and were not informed by the State of Wisconsin to conduct such a review. Moving forward, the Utilities Department will work with our engineering firm to conduct a review for suspended and debarred vendors prior to contracting with a specific vendor. We will implement this protocol as of September 15, 2025. Official Responsible for Ensuring the Corrective Action Plan: Travis Thull Planned Completion Date for the Corrective Action Plan: September 2025

Condition: YMCA did not retain evidence to support procedures were performed to ensure a vendor was not suspended or debarred before entering into a covered transaction. Planned Corrective Action: YMCA relied on outside legal counsel for guidance in the procurement process. In the future, YMCA will perform this procedure or ensure that legal counsel performs this procedure. Contact person responsible for corrective action: Phillip E. Platz, CFO Anticipated Completion Date: Immediate

Condition: The entity did not retain required support; rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Planned Corrective Action: Although YMCA performed the proper procedures, the passage of time resulted in a mis-placing of the supporting documentation. YMCA relied upon legal counsel to retain the documentation. This was a unique and one-time award. In the future, YMCA will take responsibility for the retention of the supporting documentation. Contact person responsible for corrective action: Phillip E. Platz, CFO Anticipated Completion Date: Immediate

Procurement Policy Recommendation: We recommend that management and governance review procurement requirements and create a procurement policy as necessary to ensure compliance with Uniform Guidance and retain supporting documentation for any vendors in excess of the micro purchase level. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WCEDC will develop a procurement policy that is in compliance with Uniform Guidance Name(s) of the contact person(s) responsible for corrective action: Executive Director Jeff Mikorski Planned completion date for corrective action plan: Board approval by February 2026 Board Meeting

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Health System is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Health System will create a procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. Contact Person: Daniel Cooper, Vice President of Finance and Accounting Expected Completion Date: December 31, 2025

Management will continue strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. Purchase orders will no longer be included in any submissions. Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained.

Finding 2024-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, a deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2024, the Town did not comply with the required procurement policies and procedures in place as it related to expenses charged to the major program requiring procurement procedures. One of the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78 Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2023-003 Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: CFO Estimated Completion Date: January 2025 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

IBBG will develop and adopt a written procurement policy that is consistent with the Uniform Guidance, 2 CFR §§200.318–200.326, and applicable state and local laws. The policy will outline procurement methods, competitive bidding requirements, conflicts of interest, and documentation standards. In addition: • A draft policy will be prepared by the I Be Black Girl leadership, the finance committee, and D&K Financial LLC. • The Board of Directors will adopt the final policy. • Training will be provided to staff involved in procurement to ensure consistent implementation of the procurement process.

Management Response: The Organization will establish a procurement policy in 2025. Anticipated Completion Date: 12/31/2025 Responsible Party: Board of Directors

United States Department of Agriculture Federal Assistance Listing #10.855 Distance Learning and Telemedicine Grants United Stated Department of Treasury Federal Assistance Listing #21.029 COVID-19 Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Finding Summary: During the course of the engagement, it was identified that the Cooperative does not have a written policy that addresses the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Mark Vosacek Finance Manager Corrective Action Plan: The Cooperative will modify its written procurement policy 322 to include the requirements of 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: December 31, 2025

FINDING 2024-002 Material Weakness-Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Brittany Couse Contact Phone Number: 765-677-2014 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Clerk Treasurer's Office will continue to check the System for Awards Management quarterly to verify any contractor is not debarred. Further, the office will now check for contracts that exceed the $25,000 threshold that require such inquiry. Anticipated Completion Date: Immediate

Professional and Cultural Exchange Programs - Citizen Exchanges - Assistance Listing No. 19.415 Recommendation: We recommend that the Foundation review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: American Institute For Foreign Study Foundation, Inc. does not agree with the finding. During a visit by representatives of BEGA the existing procurement policy was shared with those representatives. They approved of it and did not recommend any changes. However, a compliant policy that complies with CFR sections 200.318 through 200.326 will be developed. Name of the contact person responsible for corrective action: James Mahoney, CFO Planned completion date for corrective action plan: August 31, 2025

Item: 2024-001 Assistance Listing Number: 21.027 Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Arizona State Office of the Governor Pass-Through Grantor Identifying Number: Unknown Award Year: January 1, 2022 to December 31, 2024 Criteria: In accordance with 2 CFR § 200.318 - General procurement standards - the entity must use its own documented procurement procedures which reflect applicable. State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR § 200.318. Condition: The Organization’s procurement policy and related procedures do address the provisions of 2 CFR § 200.318; however, the Organization has not retained documentation to support that the policy is being adhered to. Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: December 31, 2025 Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will revise its internal control procedures to ensure that documentation is retained to support adherence to its own procurement policy.

2024-005 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: There is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and have taken steps to strengthen compliance with procurement policies. We have established additional documentation requirements for all procurements, ensuring that each transaction clearly reflects adherence to policy, including vendor selection rationale and approval workflows. Procurement policies are being updated to incorporate explicit internal controls and approval processes. Staff involved in procurement will receive guidance on these updated requirements. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2025

Corrective Action Taken Management concurs with the finding. The Organization transferred $151,099.42 from its operating funds back into the SFSP program account prior to the financial statements being available to be issued, thereby restoring the unallowable charge. Additionally, to prevent recurrence, the Organization obtained competitive bids and received approval for a written payroll services contract before June 2025, in advance of the start of the camp season (i.e. the Organization’s operating period). This process was conducted in accordance with federal procurement requirements. Planned Ongoing Corrective Action: The Organization has strengthened its procurement and contract approval procedures to ensure all future contracts funded by the SFSP are subject to competitive bidding, documented in writing, and approved by the State agency prior to charging costs to the program. Responsible Official: Chaim Mendel Friedman, Camp Program Administrator, is responsible for overseeing corrective actions and ensuring compliance with procurement standards and cost allowability requirements. Completion Date of Corrective Actions: Corrective actions were completed prior to the date the financial statements were available to be issued, with continuing oversight in subsequent program years.