Corrective Action Plans

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

2025-002 – Lack of Written Policies and Procedures. 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. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026

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.

2024-004 Improve Internal Controls Over Procurement Federal Agency: Department of the Treasury Award Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: 2024 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria: Per 2 CFR 200.318–200.327, non-federal entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards set forth in the Uniform Guidance. For purchases exceeding the micro-purchase threshold, procurement must include documented procedures, full and open competition (unless an exemption applies), and executed contracts. All contracts must be fully executed and amendments provided for any changes to terms or scope. Additionally, any exemption from competitive bidding must be documented, and only applies to the period and scope approved. Suspension and debarment checks must also be performed and documented for covered transactions with vendors. Condition: During our testing of one procurement transaction under the SLFRF program, the Town received an exemption from bidding requirements typically required under Massachusetts’ state law. The exemption was due to an initial emergency procurement; however, expenditures continued to be incurred after the initial emergency ended and the associated contract’s substantial completion date. The Town did not provide contract amendments to extend the contract, nor did it perform additional procurement procedures for expenditures that occurred after the emergency period ended and outside the scope of the exemption. In addition, the contract with the vendor was not countersigned by the Town and therefore a fully executed contract did not exist. Further, suspension and debarment checks for vendors were not retained as required. Cause: The Town did not ensure contracts were fully executed prior to commencement of work, did not maintain documentation or perform procurement for additional expenditures incurred after the completion date of the original contract and outside the scope of the emergency exemption, and did not maintain documentation of required suspension and debarment checks. Effect: Failure to obtain a fully executed contract, perform and document suspension and debarment checks, and appropriately document or procure additional services beyond the contract term increases the risk of noncompliance with federal procurement requirements and may expose the Town to possible unallowable costs, conflicts of interest, or ineligible vendor participation. Recommendation: The Town should implement policies and procedures to ensure all contracts are fully executed prior to work commencement, and any extensions or additional services beyond the original contract are properly documented via contract amendments or appropriate procurement methods in accordance with Uniform Guidance. The Town should also ensure continued monitoring and documentation of procurement exemptions and maintain documentation of all suspension and debarment checks for vendors paid with federal funds. Views of Responsible Official: The Town implemented a purchasing policy to ensure compliance with federal awards required under the uniform guidance. The adopted policy addresses the concerns identified in 2024-004.

AEA agrees with the finding. Management acknowledges that, while the organization followed procurement guidance contained in the Weather Assistance Program Policies and Procedures Manual, it did not formally adopt an organization-wide written procurement and suspension and debarment policy fully compliant with 2 CFR Part 200.317–200.327. AEA will formally adopt a written procurement policy that incorporates all applicable Uniform Guidance requirements, including procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and procedures for suspension and debarment verification for covered transactions. Management will also implement related procedures and control documentation to support consistent application of the policy across federally funded programs. AEA will provide training to relevant personnel and will maintain documentation evidencing procurement review and suspension/debarment verification, where applicable. Management believes these corrective actions will bring the organization into compliance and reduce the risk of future noncompliance.

Finding Number: 2024-003 Planned Corrective Action: Medina County acknowledges the deficiencies identified related to procurement documentation and suspension and debarment compliance under the Federal Transit Cluster. To address these issues, the County has implemented the following corrective actions: 1. Suspension and Debarment Verification Controls Effective immediately, prior to execution of any covered transaction funded in whole or in part with federal funds that is expected to equal or exceed $25,000, the Transit Department will verify vendor eligibility by performing a search of the System for Award Management (SAM.gov). Evidence of the SAM search, including the date performed and results, will be retained in the procurement file. In addition, all federally funded procurement contracts will include a standard suspension and debarment certification clause, or alternatively, a signed vendor certification will be obtained and retained when applicable. 2. Standardized Procurement Documentation The County will implement a standardized procurement checklist to be completed for all Transit procurements. This checklist will require documentation of: o The rationale for the method of procurement o The basis for contractor selection or rejection o The selection of contract type o The basis for contract price Completed checklists and supporting documentation will be maintained as part of the official procurement file in accordance with 2 CFR § 200.318 and the Medina County Transit Purchasing Policies and Procedures Manual. 3. Supervisory Review and Oversight The Transit Director, or designee, will perform a documented supervisory review of each procurement file prior to contract execution to ensure all required federal and County documentation is complete. No procurement will proceed without evidence of this review. 4. Training and Accountability Staff involved in Transit procurement activities will receive refresher training on federal procurement requirements, including suspension and debarment and procurement documentation standards. Compliance with these procedures will be monitored on an ongoing basis. Anticipated Completion Date: Implemented immediately and fully operational by March 31, 2026 Responsible Contact Person: Shannon Rine, Transit Director

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

The Organization will develop and implement written procurement policies and procedures that comply with Uniform Guidance and ensure consistent application across all procurement activities.

Audit Finding Reference: 2024-003 Improve Internal Controls Over Procurement Planned Corrective Action: The Town will review and revise its procurement procedures to ensure that federal requirements under the Uniform Guidance are followed for all federally funded transactions. For future federally funded contracts, the Town will maintain documentation demonstrating adherence to Uniform Guidance procurement requirements, including appropriate justifications for exemptions. The Town will ensure program staff are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: February 2, 2026

Audit Finding Reference: 2024-005 Improve Procurement Procedures Planned Corrective Action: The Town will revise its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town will ensure adequate documentation is retained for all federally funded procurements, and that procurement staff and grant managers are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: Management has made staff aware of the Federal procurement requirements associated with Federal grants and will work with grant managers, finance and procurement department staff to ensure this requirement is implemented in fiscal year 2026; on or about March 18, 2026.

Improve Controls Over Procurement Procedures (Material Weakness, Compliance Finding) Planned Corrective Action The District has reviewed procurement procedures related to the Child Nutrition Program and has taken corrective action to ensure compliance with federal procurement requirements under 2 CFR 200.318–200.326. All food service vendors are now procured through appropriate procurement procedures, including competitive solicitation and documentation of vendor selection as required by federal regulations. The District will maintain procurement records including solicitations, bids or quotes received, vendor selection documentation, contracts, invoices, and payment records. The Business Offi ce will work with the Food Service Department to ensure that all future procurements under federal programs follow required federal, state, and local procurement standards. Staff responsible for procurement will be reminded of documentation and competitive bidding requirements. Procurement documentation will be periodically reviewed by the Business Offi ce to ensure ongoing compliance. Name of Contact Person and Completion Date Nancy J. Konisky, Business Manager Completion Date: Implemented March 1, 2026

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non-compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

The district will create an SOP for procurement activities moving forward as well as making sure to train staff responsible for procurement to ensure compliance with Federal compliance.

The procurement policy will be formally reviewed and revised to ensure full alignment with 2 CFR Part 200.317–200.327. The updated policy will clearly outline all allowable procurement methods, including micro-purchases, small purchases, sealed bids (formal advertising), competitive proposals, and noncompetitive procurements. Management expects to have this implemented by April 1, 2026. The process is being monitored by Anthonia Ibe, Chief Financial Officer.

Finding 2024-003 Material Weakness in Internal Control over Compliance Name of responsible official: Evan Howard – Business Manager Corrective action: The municipality is in the process of reviewing roles, responsibilities, and job descriptions to ensure appropriate segregation of duties and proper internal controls, in accordance with the Corrective Action Plan. The plan has not yet been formally adopted. Anticipated completion date: June 30,2026

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

View of Responsible Official: A written SOP was developed for determining allowable costs and procurement requirements in accordance with the applicable CFR to guide key finance staff with responsibility for federally eligible expenditures. Anticipated Completion Date: April 30, 2026 Responsible Contact Person: Rhonda Williams, Financial Director

2024-005 – Procurement and Suspension, and Debarment – Internal Control over Procurement and Verification Against the System for Award Management (“SAM”) City’s Corrective Action Plan: The City acknowledges the finding and is in the process of implementing a formal procurement policy. This is currently under development and is expected to be approved by FY-26. To address these issues, the City will implement standardized procurement procedures requiring the use of purchase orders and direct invoicing, documented approvals, and verification of vendors’ eligibility for all projects. Procurement policies will include suspension and debarment checking using SAM.gov, and all supporting documentation will be retained in procurement files. Staff involved in procurement and grant management will receive training to ensure consistent compliance with the updated procedures and federal regulations. Responsible Person: Procurement Manager, Grants Manager, and CFO Expected Implementation Date: FY- 2026.

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained.

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager