Corrective Action Plans

Item: 2024-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agency: State of Arizona, Office of the Governor Compliance Requirement: Procurement, suspension and debarment Criteria or Specific Requirement: In accordance with 2 CFR § 200.318 – Procurement Standards, the Association is required to maintain records to sufficiently detail the history of each procurement transaction, including the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The Association did not retain documentation regarding the procurement procedures performed over one of the vendors tested. Name of Contact Person: Debbie Hann, Interim CEO Phone Number: (602) 306-4000 Anticipated Completion Date: February 2026 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. To address the auditor’s recommendation, ASBA will update its policies and procedures to ensure compliance with 2 CFR § 200.318. This will include implementing a formal procurement process with clear guidelines for competitive bidding, documentation, and approvals. Management will also establish a system to monitor procurement activities regularly, ensuring ongoing adherence to the updated policies and regulations.

Contact Person – Pattie Solberg, City Auditor Corrective Action Plan – The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date – December 1, 2025

FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings of this report. Description of Corrective Action Plan: The County Highway Department has implemented a new filing system to help ensure that audit documentation is being maintained for all federal requirements. The County will maintain documentation of all bids and Letter of Interests (LOIs) received from vendors for each project for review. These files are maintained in their own folder with the DES# and project description on the outside. The County will also maintain documentation of the LPA Selection Review Checklist for each project for review. The County Highway Superintendent is responsible for maintaining all the files and the administrator will review/sign the checklist to ensure all the files are properly maintained. In addition, the County is currently working with the County's attorney to develop a procurement policy that includes federal regulations. Anticipated Completion Date: September 2025

FINDING 2024-004: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The town attorney will draft a standard contract that will apply to any contractors that are paid $25,000.00 or more from federal funds, prior to entering a covered transaction ensuring that their respective contractor is not suspended or debarred. The council president will review and sign the contract ensuring the suspension and debarment clause is included in all respective contracts. The town has put controls and procedures in place to ensure timely documentation of suspension and debarment checks in regard to federal awards. For purchases procured outside of a contractual agreement, the town will require all vendors to self certify prior to entering into a transaction. The town will implement a procurement policy that conforms to the current requirements of CFR 200.318 for micro-purchases, under $10,000.00, the disbursing officer will only require board approval. For small purchases, between $10,000.00 and $150,000.00, three quotes must be obtained and a contract awarded. For purchases that exceed the simplified acquisition threshold, the town must allow for full and open competition in the form of a sealed bid process and awarding a contract. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Urban Development 2024-002 Continuum of Care – Assistance Listing No. 14.267 Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in the procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address this finding Share & Care House is developing and adopting a Suspension and Debarment Policy. The policy requires verification that all vendors, contractors, and subrecipients with transactions totaling $25,000 or greater have not been suspended or debarred from participation in federal programs before entering into a covered transaction. Verification will be conducted by checking the System for Award Management (SAM.gov) Documentation of the verification will be maintained in procurement and contract files. Name(s) of the contact person(s) responsible for corrective action: Celina McKenney Planned completion date for corrective action plan: 10/15/2025 If the Department of Housing and Urban Development has questions regarding this plan, please call Celina McKenney at 253-840-3402 ext. 772. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in the procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: [Describe action planned or taken]. Name(s) of the contact person(s) responsible for corrective action: [Insert name] Planned completion date for corrective action plan: [Insert date] If the [Cognizant or Oversight Agency for Audit] has questions regarding this plan, please call [Insert name] at [Insert Telephone Number].

Finding ref number: 2024-001 Finding Caption: The District did not have adequate written internal controls in place to ensure compliance with federal procurement requirements.Name, address, and telephone of District contact person: Jeff Alderson 186 Iron Horse Court Suite 100 Yakima, WA 98901 509-453-8702 Corrective action the auditee plans to take in response to the finding: This was the Districts first experience with federal funding. We have practiced appropriate internal controls but neglected to have a written formal policy. Upon realizing that we needed a formal written policy we drafted the steps we utilized to procure our contractor and supplies. That draft was then brought through our commissioner’s approval process. It was accepted formally by our Board of Commissioners on May 2024. Anticipated date to complete the corrective action: Completed May 2024

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional procurement policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

Finding Number: 2024-003 Finding Title: Procurement, Suspension, and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Lisa DeBoer – Director of Business Management Jenny Severson – Fiscal Officer Tiffany Bailey – Fiscal Officer Corrective Action Planned: The planned corrective action is to improve and update the agency guidelines and policy for procurement and implement a process with supporting documentation that ensures federal requirements are met. Anticipated Completion Date: November 30, 2025

Finding Number: 2024-002 Anticipated Completion Date: 10-31-2025 Responsible Contact Person: Mark Bridenbaugh, CEO Planned Corrective Action: The organization does have an existing Procurement Policy that is compliant with 2 CFR Section 200.320 for federal grant expenditure related procurement methods. This policy will be reviewed with all Officers, Directors and fiscal staff who are involved in managing any grant program or related purchases. Review and training will occur within the next month. Proper documentation, consistent with the policy, must be reviewed and approved by the CEO, CFO or designee prior to the purchase being made. Documentation will be kept by both the grant Project Director and the approving official.

FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has a longstanding contractual relationship with an engineering firm with extensive knowledge of the City’s water department. The city has put controls and procedures in place to ensure services are bid where federal awards are involved and the dollar amount of such services is expected to exceed the simplified acquisition threshold. The City will review its procurement policy and amend where necessary to conform to the current requirements of CFR 200.318. The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. Anticipated Completion Date: January 1, 2026

FINDING 2024-001 Finding Subject: Department of Transportation Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Brad King Contact Phone Number and Email Address: 765-648-6171 bking@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. The City has implemented procedures to ensure the proper documentation of quotes taken where applicable. Anticipated Completion Date: September 1, 2025

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the federal program: • One instance where the Cooperative followed a bid process, however, the documentation was not retained to support the selection. Additionally, the contract with the vendor was missing required contract provisions in accordance with Uniform Guidance. • Two instances where the Cooperative did not follow the procurement process as detailed in the procurement policy and did not have any formal documentation or contract in place with the vendor. • Three instances where the Cooperative entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Corrective Action Plan: We plan to review our procurement policy with all parties that may enter into contracts for the cooperative to be sure the policy reflects our needs and that procedures are being followed. We will also implement a review process where management signs off on bid selection documentation, including verification that vendors are not suspended or debarred. Responsible Individuals: Hollee McCormick, General Manager and Jason Troendle, Director of Operations and Engineering Anticipated Completion Date: November 2025

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-004 Finding caption: The city did not have adequate internal controls and did not comply with federal procurement requirements. Name, address, and telephone of City contact person: Lisa Wolff, Finance Director PO Box 128 Longview, WA 98632 (360) 442-5036 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). In response to the issues identified, the city is taking the following steps: 1. Rewriting Procurement Manual o The city passed a resolution in August to update the city’s procurement policy. The new policy will include flow charts and links to Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and applicable RCWs to ensure the City is following required procurement processes. The procurement policy updates are expected to be completed by the end of 2025. 2. Checklist Creation o The city will create a checklist as part of the procurement policy. This checklist will guide city staff through the proper processes and document the steps taken. Status of Identified Errors • The agreement with the organization currently operating the city’s homeless shelter is expiring in the near future. The city is currently going through the bidding process for a new operator. Conclusion The City acknowledges that the procurement policy was not followed upon receipt of grant funding. The City is working on new policies and procedures that will ensure that proper procurement processes are followed moving forward. Upon completion of the updates to the procurement process, the City can supply a copy of the new process at your request. Anticipated date to complete the corrective action: No later than December 31, 2025

To address this finding, AACC will adhere to the financial policies and procedures properly documenting procurement decisions for goods and services with a total cost of $25,000 or greater. (Financial Policies and Procedures, pages 25, 45). In the event of “Sole Service Providers”, staff will document the circumstances as such for recording. Effective immediately, all projects will be reviewed by a team assembled within the association, (Staffing to be determined by the President/CEO). A staff member, housed in the President’s Office with research and using a scorecard, assess and present potential opportunities to the President/CEO for approval to proceed. Approved opportunities will be reviewed by the team along with the department head making the request. There will be a collaborative effort of the scope of the project along with the budget necessary to implement the project. All parties will sign-off on their respective steps prior to the full package being presented to the President/Chief Executive Officer for final approval. A checklist will be used to monitor the process. All vendors written into the agreement will be vetted through a process that will include the rationale for their selection.

Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original intergovernmental agreement (IGA) and determined that the agreement had not expired and required no additional board approval or agreement. This is why each year since, Legal has provided authorization for purchase order creation and payment to Chicago Police Department (CPD). The agency is working with CPD to formalize a new IGA. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025

Finding 2024-001 Condition Quarterly reports submitted were not reviewed by someone other than the preparer. The quarterly reports are both prepared and signed by the Administrative Services Manager. While the information used in preparing the reports is gathered from the City and Black & Veatch (Construction Manager) is detailed and goes through reviews prior to being provided, there is no independent review of the report prior to authorization and submittal. Corrective Action Plan Quarterly reports will continue to have information gathered from the Construction Managers and the City of Waukesha Engineer working on the projects. The Senior Accountant or other appropriate staff member will prepare the quarterly report and the Administrative Services Manager will then review the report, sign it, and submit the quarterly report to the EPA. Name(s) of Contact Person(s) Responsible for the Corrective Action: Cortney Nagel, Administrative Services Manager Anticipated Date of Completion: 09/30/2025

Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2024 COVID-19 - Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material NoncomplianceFinding Summary: During the course of the engagement, it was identified that the Cooperative's written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative did not follow procurement, suspension, and debarment procedures required under the Uniform Guidance prior to entering into contracts with vendors. Responsible Individuals: Director of Administration Services, General Manager Corrective Action Plan: The Cooperative will update its Board Policy No. 205 to include the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative will maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2025

2024-005 Improve Internal Controls Over Procurement Management Response and Corrective Action Plan (DPW): Management concurs with the finding. The City acknowledges that one procurement, a rental for a piece of equipment under the SLFRF program for ARPA Replacement Roads and Sidewalks, lacked sufficient supporting documentation to demonstrate compliance with federal procurement standards. The City is committed to strengthening internal controls to ensure all federally funded procurements comply with 2 CFR 200.317–200.327, Treasury’s SLFRF Compliance and Reporting Guidance, and applicable state and local procurement laws. Planned Implementation Date: 12/17/2025 Person Responsible for Corrective Action: Julianne Pelletier

Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends regular review of the Organization's procurement policies to ensure they continue to meet procurement standards, as set by Uniform Guidance, and they continue to be consistently implemented. CLA also recommends reviewing internal controls surrounding procurements to ensure they are sufficient to prevent noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previous corrective actions were completed in April 2024 upon receipt of our FY 2022 audit and further amended in August 2024 during FY 2023 audit to update internal procurement policies to match Uniform Guidance requirements. We believe these corrective actions would have captured most, if not all, of the incidents in February and March 2024 that contributed to this repeat finding. That said we will continue to regularly review the Organization’s procurement policies to ensure they meet procurement standards. We also aim to implement an annual internal control review to ensure they are sufficient to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/01/2025

Finding 2024-003: Noncompliance – Procurement Policy The entity does not have a documented procurement policy. As a result, there is no formal guidance to ensure that procurement transactions are conducted in accordance with applicable federal regulations, including requirements related to full and open competition, appropriate procurement methods based on dollar thresholds, and verification of suspension and debarment. Planned Corrective Action: Management has developed and put in place a written procurement policy effective May 1, 2025. James Frederick, COO, is responsible for the corrective action plan.

WEST MICHIGAN FOOD PROCESSING ASSOCIATION CORRECTIVE ACTION PLAN DECEMBER 31, 2024 West Michigan Food Processing Association respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit period: Year ended December 31, 2024. District Contact Person: Marty Gerencer, Contracted Executive Director The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding: Federal Awards and Questioned Cost Finding 2024-01 Recommendation: We recommend that West Michigan Food Processing Association develop and implement comprehensive written policies and procedures to address the requirements of the Uniform Guidance. These should be tailored to the Association’s structure and operations and cover all applicable federal compliance areas. Management should also establish a process to periodically review and update these documents to ensure continued compliance. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future. Finding: Financial Statement Audit Finding 2024-02 Recommendation: We recommend implementing a compensating control to mitigate this risk, such as: ➢ Requiring documented approval by a board member or other authorized individual prior to processingdisbursements, or ➢ Providing a board member or finance committee member with view-only online access or automatedbank alerts to review all cleared transactions. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Montesano January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls in place to ensure compliance with federal procurement requirements. Name, address, and telephone of City contact person: Gretchen Sagen, CFO/Clerk 112 N Main Street Montesano, WA 98563 (360) 249-3021 Corrective action the auditee plans to take in response to the finding: To address this finding and strengthen documentation, the City is taking steps to: 1. Adopt a written City procurement policy that incorporates federal, state, and local thresholds and methods, consistent with 2 CFR 200.318–327; and 2. Update our standards of conduct to explicitly include all conflict-of-interest provisions required under federal regulations. These corrective actions will supplement the existing WSDOT oversight framework, provide auditors with clear reference points for internal controls, and ensure continued compliance with Uniform Guidance requirements. Anticipated date to complete the corrective action: October 2025

2024-002: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School's reasoning for a noncompetitive procurement. Repeat Finding: Similar to prior year finding 2023-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Controller's office will provide instruction for all departments on retrieving letters from their vendors. This training is crucial for ensuring compliance with Suspension & Debarment regulations and establishing a robust system of internal controls for federal funds. Anticipated Completion Date: December 31, 2025