Corrective Action Plans

Re: Management’s Response & Corrective Action Plan to Procurement Policy & Procurement Action Documentation (2024-004) The Wilmington Land Bank adopted a written Procurement Policy on September 11, 2024. At one property, however, the policy was not fully followed. The Land Bank initially considered the work a continuation of an existing project, but it was later determined that it should have been bid separately under the Procurement Policy. To strengthen compliance with the Procurement Policy going forward, the Land Bank will hold weekly internal staff meetings and weekly meetings with the City of Wilmington. These meetings will include a review of project updates and related procurement actions. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

2024-003 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not follow their documented procurement procedures for approving one contractor. Corrective Action Plan: All procurement procedures will be followed as documented in YWCA St. Joseph financial policies. Person(s) Responsible for Implementation: Danielle Brown, CEO, dbrown@ywcasj.org, 816-232-4481

RUMC follows applicable federal grant guidelines and requirements, including adherence to the three-bid policy and related procurement standards. However, there were two factors that impacted our ability to provide complete supporting documentation during the audit period: (1) the departure of the project manager who was responsible for maintaining procurement records for the project, and (2) a cyber event in 2023 that resulted in the loss of certain files and supporting documentation. While these circumstances limited our ability to produce documentation evidencing compliance, management affirms that the required procurement steps were performed and that RUMC remains in adherence with federal grant requirements. To further strengthen compliance, RUMC has established a Construction Grant Committee to ensure full adherence to all grant requirements. This committee is responsible for reviewing procurement actions, verifying compliance with the three-bid requirement, ensuring proper documentation is retained, and monitoring procurement processes throughout the life of each project. These corrective actions will ensure that complete and verifiable records

Finding 2024 002 – Activities Allowed or Unallowed and Allowable Costs/ Cost Principles, and Procurement Federal Agency: U.S. Department of Transportation Program Name (ALN): Public Transportation Emergency Relief Program (ALN 20.527) Federal Grant Numbers: NJ 44 X004 02 (Federal fiscal years 2012–2025) Contact Person: Fatima Castellanos, PATH, Finance & Business Planning Manager, 201-216-6459. Corrective Action: Although federal funds were not received for this expenditure, PATH acknowledges an internal control deficiency regarding the recognition of grant funding for work performed under standard nonfederal engineering call-in contracts. PATH will continue to work collaboratively with the Engineering and Procurement Departments to strengthen internal communications and reinforce adherence to established protocols governing capital projects that are eligible for federal funding. Procurement will provide and document targeted procurement training for awareness to Engineering and PATH staff on adhering to procurement protocols during the execution of contract work that is anticipated to receive federal funding. Anticipated Completion Date: Changes to the controls and processes will be implemented and training provided in the fourth quarter of 2025.

Finding # 2025-001 Type: Immaterial noncompliance U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing #11.441 Finding: The Organization’s fiscal policies and procedures do not meet the required federal standards for procurement set out at 2 CFR sections 200.318 through 200.327. The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Corrective Action: Management will work on revising the Organization’s procurement policies to incorporate the necessary provisions. Anticipated Completion Date December 2025

Going forward the Center will prepare and implement a procurement policy in accordance with Uniform Guidance requirements and ensure there is documentation that verifies vendors are not suppressed or debarred prior to entering into contracts with the vendors.

Giraffe Laugh will update the current procedural manaul to ensure that proper action is taken at the time invoices are submitted for approval. We anticipate having the procedure manual updated and ready by the end of the first quarter of the fiscal year 2026. Wihle proper protocols were being follwed, the manual was not adequately updated to reflect best practices. Anticipated completion date: March 31, 2026

Individual(s) Responsible: LaNita Perez, Controller and AP Specialist Action: Management will ensure that all procurement transactions comply with established policies and procedures. Competitive bidding, documentation of procurement methods, justification for sole-source contracts, and price/cost analyses will be required for all applicable purchases. Staff will receive training on procurement requirements under Uniform Guidance. Management will monitor procurement activities and verify that each purchase is supported by proper documentation. Compliance with policies and procedures will be checked regularly. Anticipated Completion Date: December 31, 2025

Adopting procurement policy that complies with UG procurement standards and distributed it to all staff with purchasing authority. The ED and Treasurer are currently developing a checklist that will be included as part of initiating contracts or purchases over the procurement threshold and that it is saved along with other grant documents. The bookkeeper will check the SAM data base for disbarment notices prior to queuing bills for amounts greater than $5,000 for payment

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Missouri Department of Transportation Audit Finding Number: 2024-015 - MoDOT Monitoring of BABA Provisions Name of the contact person responsible for corrective action: Todd Grosvenor, MoDOT Financial Services Director, 573-751-4626 Anticipated completion date for corrective action: January 12, 2026 Corrective action planned is as follows: MoDOT will develop written policies and procedures for monitoring contractor and subrecipient compliance with the Build America, Buy America (BABA) domestic preference provisions for Infrastructure Investments and Jobs Act (IIJA)-funded projects. To date, MoDOT has drafted the policies and procedures, which are being reviewed by the Federal Highway Administration (FHWA). The next available document submission date for policy revisions is November 27, 2025. MoDOT will submit the FHWA-approved monitoring plan to be added to MoDOT’s policies by that deadline. The policy is scheduled to be published by January 12, 2026. MoDOT will provide training to the department’s resident engineers in November 2025.

Corrective Action Plan for Finding 2024-01 Type of Finding: Internal Control and Compliance - Compliance and Material Weakness Deficiency over Procurement and Suspension and Debarment Federal Program: U.S. Department of Treasury, American Rescue Plan Act (ARPA) Federal Assistance Listing No.: 21.027 Condition: During the single audit, there was a finding of no documentation to support a competitive bidding or procurement process for certain vendor contracts, as required by federal procurement standards. Corrective Actions 1. Revise Internal Procurement Policy A. Action: The organization will revise its existing procurement policy to adhere with federal requirements for competitive bidding, including thresholds for different procurement methods (e.g., micro-purchases, small purchases, sealed bids, competitive proposals). The revised policy will clearly define the documentation required for each step of the procurement process. B. Responsible Party: Kimberly Royster (CFO) C. Anticipated Completion Date: October 15, 20252. Provide Mandatory Staff Training A. Action: The organization will train all employees, including those in finance, program management, and administration, on the new procurement policy and process. The training will emphasize the importance of compliance with federal regulations and the specific documentation requirements. B. Responsible Party: Wayne Lawson (HR) and Laura Connelly C. Anticipated Completion Date: November 12, 2025 3. Implement the Revised Procurement and Documentation System A. Action: The organization will implement the new procurement process for all procurement activities. This process will require documentation of all stages of the procurement process, from the initial request to the final contract award. This will ensure that a complete audit trail is maintained for every purchase. B. Responsible Party: Laura Connelly C. Anticipated Completion Date: November 12, 2025 4. Conduct Post-Implementation Monitoring A. Action: The organization will enlist the services of the external audit team to review the updated procedures. This will serve as a check to ensure the new policy meets federal requirements. B. Responsible Party: Current Auditor C. Anticipated Completion Date: December 31, 2025

The audit identified gaps in our procurement policies and procedures. In response, updated procurement policies have already been drafted. These policies align with federal requirements, strengthen internal controls, and establish clearer guidelines for competitive bidding, documentation and approval processes. The draft policies are currently under review by the Executive Director and will be finalized and implemented promptly.

Procurement, Suspension and Debarment Program: Program: ALN 66.458 Clean Water State Revolving Fund ALN 66.468 Drinking Water State Revolving Fund Condition: The City’s procurement procedures do not conform to Uniform Guidance requirements. Corrective Action Planned: The City will update procurement procedures to conform with Minnesota statutes and Uniform Guidance. Officer Responsible for Ensuring CAP: Goldie Smith, Clerk/Treasurer Planned Completion Date: 12/31/2025

Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026

Reporting - Reportable Findings and Questioned Costs for Federal Awards Contact Person Marc Taylor, CFO E-Mail: Marc@chiefseattleclub.org Corrective Action Planned This finding occurred because of a lack of both procurement knowledge and staff oversight over a contractor handling the procurement for Eagle Village. Thanks to this finding, our real estate team has gained a better understanding of federal procurement requirements. Our auditor provided us with a procurement checklist, which we began using and will ensure that we comply with our procurement policy and better document future procurements. Anticipated Completion Date September 30, 2025

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