Corrective Action Plans

Program: Summer Food Service Program CFDA: 10.559 Finding Type: Noncompliance / Significant Deficiency Issue: Purchases from two food vendors exceeded the micro-purchase threshold without documented price comparisons or quotations. Management's Response: Response: Management acknowledges the importance of adhering to federal procurement standards, including the requirement for competitive pricing and documentation for purchases exceeding the micro-purchase threshold. Corrective Action Taken: Staff involved in procurement have been trained on 2 CFR 200.318-200.326 to ensure understanding of federal procurement requirements. A procurement forecast is now developed at the beginning of each grant cycle to identify vendors likely to exceed the micro-purchase threshold. . For all vendors expected to exceed $10,000 in purchases, the YMCA will obtain and retain at least three price comparisons or quotations. A procurement checklist and documentation log have been implemented to ensure compliance and audit readiness. Responsible Individuals: Karrie Stanford and Gina Franklin Completion Date: Plan has been implemented as of the date of audit submission.

District has been in discussion with our attorney and have already got a new ordinance written and put into effect as of June 1, 2025. CVDWSD currently has a procurement policy as a ordinance.

Action taken in response to finding: • LMC Staff will be re-trained on the process and importance of retaining documentation that SAM.gov was used to verify that a vendor was not suspended, debarred or otherwise excluded from participating in the transaction prior to contract. • LMC staff will review the OIG exclusions list prior to onboarding or signing contracts with vendors. • LMC staff will print and retain proof of each review for reporting purposes Name(s) of the contact person(s) responsible for corrective action: Melissa D’Onorio, CEO, and Donna Landy, CFO. Planned completion date for corrective action plan: 07/14/2025

The Town of Ramah is in the process of creating a Procurement Policy.

Retrained all staff on procurement policies – the approver misunderstood and thought that because this was a reimbursed cost that the higher level signature was not needed, so we have clarified that approval limits apply regardless of whether it is a reimbursable cost Establishing new, more automated procurement approval process that allows us to set approval levels for each user and will reduce potential for errant approvals Ensure all new management staff receive and acknowledge the procurement policy

Finding 2024-002: Federal Transit Cluster – Procurement and Suspension and Debarment (Noncompliance and Significant Deficiency in Internal Control) Condition: In some procurement files, TANK had missing documentation of procurement history, missing required contract clauses, lack of evidence of contractor responsibility determination and missing lobbying and Buy America certifications. Corrective Action: TANK implemented new procurement procedures and a revised checklist which outline and confirm all of the FTA-required clauses for any federal procurement. TANK documented and submitted procedures for obtaining signed lobbying and Buy America certifications in all procurements over $100,000/$150,000. TANK documented our procurement procedure which requires a responsibility determination to verify that contractors were not debarred or suspended from participating in federal awards by checking for System Award Management (SAM) certification. TANK included in the new procurement procedures an update of the record-keeping of procurement history to include elements such as rationale for the method of procurement; selection of contract type; reason for contractor selection or rejection; and basis for the contract price. Responsible Party: Lyndi Whiteker, Procurement Analyst Anticipated Completion Date: Complete and findings were closed between 7/19/2024-11/26/2024.

FINDING 2024-002 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas A. Dippel, CPA Contact Phone Number and Email Address: (812) 683-2211 / ct@huntingburg-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with the City’s attorney to revise its current policy to include federal regulations and procedures related to Procurement and Suspension and Debarment. Once revised, the City will follow its policy to ensure compliance with the compliance requirement. Anticipated Completion Date: September 30, 2025

Finding 2024-005 – Lack of Written Policies Required by the Uniform Grant Guidance Contact Person: Nicole Roberts, Village Manager Planned Corrective Action: The Village will develop and adopt written policies and procedures to comply with Uniform Guidance requirements, including internal controls, procurement, cash management, and allowable costs. Anticipated Completion Date: December 31, 2026

Corrective Action: 1. Develop procurement procedures for procurement transactions under Federal awards or subawards, including verification that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. 2. Provide training to relevant staff on the new procedures for procurement transactions, including the verification of suspension and debarment for any subrecipient awards and the importance of compliance with federal regulations.

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Federal Financial Assistance Listing #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following • The Cooperative’s formally documented procurement policy was missing one required element as it relates to the methods of procurement. • 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 • One instance 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. • Two 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: The Cooperative has taken several steps to remedy the findings of the 2024 single audit: • In April 2025, the Board of Directors approved a revised procurement policy that includes the missing method of procurement. • Existing contracts have been amended to include required contract provision in accordance with Uniform Guidance. Any new contract will include those provisions. • All current contractors have been reviewed to ensure the vendors are not suspended or debarred. All searches have been printed and retained. Any new contractors will be reviewed prior to their selection as a vendor. • The reasoning for utilizing single-source vendors has been formally documented and signed off on by management. • All bid processes are now formally documented, including cost comparisons between vendors. Responsible Individuals: Jeremy Richert, CEO and Kelly Gibbs, CFO Anticipated Completion Date: July 2025

The College will retain all procurement documentation going forward..

Corrective action planned: Two new policies will be implemented; a board policy to cover board approvals for the bidding of large projects and an internal policy and procedure which spells out additional requirements, like requiring three written bids for large purchases. In addition, all members of the Board of Directors and senior leadership team will sign Conflict of Interest statements on an annual basis to confirm that they do not have any potential conflicts that could impact purchasing decisions. Anticipated completion date: July 31, 2025 Contact person responsible for corrective action: Steve Lindemann, Interim CFO

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Department of Homeland Security and Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: The Cooperative's procurement policy had not identified the dollar thresholds of procurement within the methods of procurement. In addition, one contract selected for testing was missing one of the required contract provisions. Corrective Action Plan: The Cooperative is working with our attorney to update the procurement policy to include the dollar thresholds of each method of procurement. We will update the procurement policy after acceptable changes are made. Responsible Individuals: Shelly Hove, CFO Anticipated Completion Date: September 2025

Identification Number: 2024-001 Finding: Procurement, Suspension and Debarment Corrective Actions Taken or Planned: The Armed Services YMCA (ASYMCA) acknowledges the control deficiency identified in the area of procurement policy and is actively addressing it to ensure full compliance with 2 CFR § 200.318 (formerly referenced as 2 CFR 300.218), which governs procurement standards for non-federal entities receiving federal awards. 1. Policy Development and Alignment with Federal Regulations ASYMCA Finance is currently compiling and formalizing procurement procedures in accordance with 2 CFR § 200.318. This initiative will result in a comprehensive, board-approved procurement policy that ensures compliance with federal requirements and strengthens internal controls. 2. Existing Policies and Controls ASYMCA already maintains consistent, documented, and approved policies in several key areas of procurement and financial management, including: • Authority of Responsibility: Delegation of authority for designating funds and obligating ASYMCA for purchases, including spending thresholds and approved personnel. • Procurement Standards: General procurement principles and internal controls. • Professional Services and Consulting Agreements • Purchase of Capital Items • Signature Authority • Legal Review • Unbudgeted Expenditures • Record Retention • Policy Enforcement and Consequences • Procedures for Invoicing, Payment Processing, and Reimbursements (Travel and Non-Travel) • Requesting New Vendors • Competition: Requirements for full and open competition in vendor selection.   3. Areas for Expansion and Integration To ensure full compliance with federal procurement standards, ASYMCA will expand its current policies to include the following areas: • Conflict of Interest: Clear guidelines to prevent personal or organizational conflicts in procurement decisions. • Methods of Procurement: Defined procedures for micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals. • Purchase/License of Technology or Software: Standards for evaluating and acquiring digital tools and platforms. • Indirect Cost: Clarification of treatment and allocation of indirect costs in procurement. • Methods of Procurement (as per federal thresholds) • Contracting with Small and Minority Businesses and Women’s Business Enterprises • Contract Cost and Price Analysis • Federal Awarding Agency Requirements 4. Implementation Timeline ASYMCA is committed to finalizing, approving, and implementing the updated procurement policy the end of the 2025 reporting period. This will include: • Internal review and legal vetting (if necessary) • Board and/or Audit Committee approval • Staff training and dissemination of the policy • Integration into operational procedures for all federally funded and non-federally funded projects Conclusion ASYMCA is committed to maintaining the highest standards of accountability, transparency, and regulatory compliance. The actions outlined above demonstrate a proactive and structured approach to addressing the control deficiency and ensuring that all procurement activities are conducted in accordance with applicable federal regulations. Anticipated completion date: December 31, 2025 Responsible Contact Person: Laura Tate-Smith, Chief Financial Officer

Finding Number: 2024-001 Recommendation: Create a procurement policy that meets the requirements detailed in 2 CFR 200.318– 200.327 Action Taken: AANA will implement a new Procurement Policy as it relates to purchases and grants supported by the MAST program. See document “MAST Procurement Policy” Responsible Contact Person for Planned Corrective Action: Dennis Siena Anticipated Completion Date: September 30, 2025

Corrective Action Planned: The USGA will enhance the procedures within its Policy for the Acquisition of Goods & Services relating to procurements utilizing Federal funding. In particular, the Policy will be amended so that adequate documentation is retained to ensure compliance with the requirements for the procurement methods described in 2 CFR §200.320. Further, the updated Policy will include additional requirements to ensure that applicable documentation of the USGA’s suspension and debarment verification procedures is retained and attached to any related purchase order in the USGA’s ERP system. At the time of the Policy’s approval by the USGA’s Executive Leadership team, the document will be shared with all employees and posted on our internal shared site where Finance related policies are stored and may be referred to. The USGA’s Finance/Accounting Department will be responsible for identifying grants to which the updated Policy applies and to assist with retaining the relevant documentation. The USGA’s Finance/Accounting Department will also develop a unique coding/project identifier to assist with ensuring that the request to purchase via a Purchase Order (PO) is visibly different than a generic PO when Federal funding is involved.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

The County Board should draft and approve policies and procedures for the procurement of contractors per the Compliance Supplement, Code of Federal Regulations, United States Codes, and Federal Acquisition Regulations to ensure the proper advertisement and selection of contractors and consultants, and to prevent conflicts of interest during the selection of contractors and consultants. Management Response: Management will draft and approve the recommended procurement policies and procedures and disseminate the information to department heads and County employees during the fall of 2025.

FINDING 2024-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Darrin Boas Contact Phone Number and Email Address: 812-522-4020; dboas@seymourin.org Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Management developed, adopted and implemented a procurement policy for federal purchases that aligns with the requirement of the 2 CFR 200 Uniform Guidance. This process includes steps within the interview and application process to ensure contractors and subrecipients are eligible (not suspended, debarred, or otherwise excluded) to enter into an agreement, contract, or subaward with the City. The contract in question was agreed to during last year’s audit and part of an overall project/grant overseen by Schneck Hospital entered into in 2021. Going forward, the Clerk Treasurer will review the agreements with the vendors who are being paid from federal grant monies to ensure that the procurement policy is being followed and proper documentation is being obtained based on the procurement method. Anticipated Completion Date: Completed. The City adopted Ordinance 35 on November 25, 2024. This was the effective date of correction.

Finding 2024-003 – Material Weakness Award No.: AL No. 15.555 and AL No. 15.074 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The following conditions were noted during the single audit: • The District was not able to provide evidence that procurements for the Mendota Pool Fish Screen and Control Structure Project and Poso Canal Bridge Replacement Project design contractors under AL 15.555 met the requirements for adequate price competition and was unable to provide documentation confirming the sole-source solicitations met the requirements of Uniform Guidance. Specifically the District was unable to provide evidence it received enough statements of qualification to have adequate price competition or complied with one or more provisions of Section 200.210(c) that allows a sole source agreement to occur. It would appear the District would need evidence that the grantor approved the sole source procurement, but was not able to provide documentation of approvals of sole source procurements by the grantors. The District also was unable to provide documentation of the advertisement of the solicitation of requests for qualifications for the Fish Screen and Control Structure Project. • The District was not able to provide adequate documentation that the Mendota Pool Fish Screen and Control Structure Project contract under AL 15.555 and Orestimba Creek Recharge and Recovery Expansion Project contract under AL 15.074 complied with Section 200.327 and appendix II to this part requiring federal contract provisions to be included in the approved contract. This resulted in the District not having evidence that the contractor certified it was in compliance with all required federal provisions. Criteria: Uniform Guidance states the following: • Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractors selection or rejection, and the basis for the contract price.” • Section 300.320(c) states “There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: (1) The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The procurement transaction can only be fulfilled by a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; (4) The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or (5) After soliciting several sources, competition is determined inadequate. • The provisions of the Brooks Act (49 United State Code, Section 1104) require local agencies to award federally funded engineering and design related contracts, otherwise know as A&E contracts, on the basis of fair and open competitive negotiations, demonstrated competence, and professional qualifications (23 Code of Federal Regulations (CFR), Part 172) at a fair and reasonable price (48 CFR 31.201-3). Both federal regulation and California state law (Government Code 4525-4529 et a) require selection of A&E consultant services on the basis of demonstrated competence and professional qualifications. Procurement by noncompetitive proposals may be used only when the award of a contract is infeasible under small purchase procedures, sealed bids or competitive proposals, as cited above. • Section 200.327 states “The non-federal entity’s contracts must contain the applicable provisions described in appendix II to this part.” Appendix II contains requirements to include in federally funded contracts termination for cause and convenience provisions, Equal Employment Opportunity provisions, Davis-Bacon Act provisions, Contract Work Hours and Safety Standards Act provisions, Clean Air Act provisions, debarment and suspension provisions, Byrd Anti-Lobbying Amendment provisions, and other provisions, as applicable. Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the requirement to maintain documentation indicating the procurement was in compliance with Uniform Guidance Sections 200.318 to 200.327 and appendix II to this part. Context: The original procurement for the consulting firm for the Mendota Pool Fish Screens and Control Structure project was performed in September 2018 and awarded in late October 2018. This procurement precedes the current staff. Staff indicated the grantor approved the Mendota Pool Fish Screen and Control Structure Project sole source procurement and the Board Resolution approving the agreement indicated the grantor approved the sole source procurement, but staff was not able to provide proof of written approval by the grantor. Recommendation: We recommend management implement additional controls over the procurement process that ensures each procurement complies with Uniform Guidance Section 200.318 to 200.326, including training of staff working on procurements of the documentation retention and other requirements under the Uniform Guidance. We further recommend the District establish a procurement folder on its server with subfolder for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals/qualifications with language that satisfies Uniform Guidance requirements, proposals received, executed contracts, certifications of compliance with federal contracting provisions by the contractor if not part of the proposal or executed contracts, documented quantitative and qualitative analysis indicating why the recommended bid was selected for approval, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. If a sole source procurement method is used, documentation showing the sole source procurement is allowable under criteria listed in Section 300.320(c) should be retained. Views of Responsible Officials and Planned Corrective Actions: Management will keep procurement folders on each procurement in the future that includes the confirmation in the recommendation and will consult with Reclamation on whether a contract amendment is necessary to document the federal contract. Estimated Completion Date of Corrective Action: Future procurement projects

The Purchasing Director for the City-Parish has the authority as provided by the Code of Ordinances to approve emergency purchases upon review of the certification of the emergency by the user department. At the beginning of 2024, the Baton Rouge Police Department noted its patrol units were in less than standard conditions and a recent Police Academy graduating class of sworn officers compounded the need for viable units. At the same time, a nationwide supply chain crisis limited the availability of vehicles for purchase. Multiple quote requests from vendors across Louisiana confirmed a lack of available inventory including the Louisiana State Contract vendor as well as a piggyback contract for the Jefferson Parish Sheriff’s Office. After an exhaustive search, a single vendor was located who had an inventory of matching vehicles on hand for offer within a limited time frame. In an effort to not compromise public safety, an emergency purchase was utilized which was signed by both the Police Chief and the Purchasing Director. As required, notice was given by publishing in the newspaper. Expected Implementation Date: June 2025 Contact person: Philip Gore, Interim Director, Purchasing Division

The amendment in question did not constitute a material change in the scope, nature, or intent of the original procurement. The additional funding awarded was consistent with the original services solicited and did not involve new activities or substantially alter the deliverables or performance standards initially procured. As such, the amendment fell within the bounds of the original competitive process and was not required to be procured. The City-Parish procurement policy allows for amendments when they do not exceed the original scope of work or introduce fundamentally different services. The amendment was processed with full documentation of cost reasonableness, continued eligibility under the applicable grant program and internal approval. Therefore, we assert that the contract amendment was executed in accordance with both HUD and local procurement requirements and no formal procurement was necessary. To strengthen internal controls and ensure full alignment with federal procurement requirements, the OCD will document and reinforce internal procedures outlining when procurement is or is not required for amendments within the original scope. Procurement training is ongoing. The OCD staff will conduct refresher training with procurement and program personnel on contract amendment procedures and documentation requirements. Expected Implementation Date: August 2025 Contact person: Kelly LeDuff, Urban Development Director, Office of Community Development

The city has updated and implemented its procurement process in FY25 to ensure that expenditures for vendors that exceed $10,000 and sole source contracts follow the correct procurement policies and procedures in accordance to MGL 30B.

Corrective Action Planned: The transit will work with NDOT and FTA as the oversight agencies to determine any necessary changes to the vehicle leases. Anticipated Completion Date: June 30, 2025 Responsible Party: Christy Warner, Transit Administrator