Corrective Action Plans

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The following corrective actions will be implemented by the School District: 1. Implement Strengthened Pre-Approval and Documentation Procedures: a. All Child Nutrition purchases will require a completed purchase request form that clearly identifies the funding source, purpose, and allowability under federal guidelines. b. Documentation (invoices, quotes, purchase orders) must be attached and reviewed by the School Nutrition Director and CFO or designee before approval. 2. Enhance Segregation of Duties: a. The individual initiating a purchase or expenditure will not be the same person approving or reconciling it. b. Monthly expenditure reviews will be performed jointly by the Finance Department and School Nutrition leadership to ensure accuracy and compliance. 3. Establish an Internal Monitoring Checklist: a. The School Nutrition Department will implement a monthly internal monitoring checklist that includes documentation review, reconciliation of expenditures, and verification of procurement compliance. The CFO will meet with the Nutrition director monthly. 4. Update Written Polices and Procedures: a. The district's Financial Procedures Manual and the School Nutrition Operations Manual will be updated by December 2025 to reflect all new internal control steps and approval requirements specific to federal expenditures. Estimated Completion Date: June 30, 2026 Contact Person: Tiffany Crockett, Chief Financial Officer Telephone: 478-946-5521 Email: tiffany.crockett@wilkinson.k12.ga.us

Finding 2024-005 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Nate Moore, Finance Director Corrective Action: The Finance Department will regularly ensure that the procurement policy for the City is followed, and will be sure that it is reviewed often to be sure that no modifications or adjustments need to be made. Anticipated Completion Date: June 30, 2026

Reference: 2024-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus Frederickson, Mayor; Patrick Reagan, City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2025

Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: The City does not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Finance Officer Corrective Action Plan: The City will establish controls to follow all applicable procurement requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: December 31, 2025

The executive level, including the finance director of SEVCA, acknowledge these weaknesses in our practice in FY24. SEVCA has renewed focus on well documented proper procurement procedures and accountability for oversight of procurement action steps by multiple team partners. The following corrective actions are in place: 1. Policy Reinforcement and Training o Conducted mandatory training for all staff involved in procurement, emphasizing the documentation requirements outlined in the Organization’s procurement policy.o Distributed updated procurement documentation checklists to ensure clear understanding of required elements for each procurement file. 2. Standardized File Documentation Process o Implemented a standardized cover sheet or checklist for each procurement file to be completed and reviewed before contract finalization. This indicates whether all required steps (e.g., solicitation of bids) were completed or, if not, the reason for deviation in standard practice. 3. Internal Review and Monitoring o Established a quarterly internal review of a random sample of procurement files to ensure compliance with documentation standards. o Assigned a staff member or team (e.g., Finance Support Specialist) to oversee this review process and report findings to Finance Director and Program Director. 4. Follow-Up and Accountability o Require program director and finance director sign-off on all procurement files over $20,000 to ensure all documentation requirements are fulfilled. o Include procurement documentation compliance as part of staff performance evaluations where relevant. Responsible Person: Finance Director, Lisa Whitney and Executive Director, Josh Davis

The School Department Failed to Check Vendors for Suspension and Debarment Before Contracting Name of Contact Person: Michael Perrone, Director of Business & Finance Corrective Action Plan: The District will apply procedures, and or processes, to document all contracts with vendors that exceed $25,000 to include verification that the vendor is not subject to suspension/debarment prior to contracting. It is important to note, that on every Middleborough Public School purchase order contains the language “The offerer certifies that they and any principals are not presently debarred, suspended, proposed for debarment,or declare ineligible for the award of contracts by any federal agency” The District believed that a vendor honoring our purchase order (Contract) was in essence certifying that they were compliant with the language on our purchase order. Proposed Completion Date: The District will immediately make the necessary changes to comply with the aforementioned finding. It would be helpful if your team would supply the District with examples from other municipalities with acceptable practices.

The Organization is in the process of revising its procurement and conflict of interest policies to ensure alignment with the requirements of 2 CFR §§ 200.318 through 200.326. During fiscal year 2026, the Organization will adopt updated written procedures and implement a formal internal control checklist to verify compliance with federal procurement standards across all grant-funded purchases. Staff responsible for procurement will receive training on the revised policies to ensure consistent application moving forward.

Corrective Action Plan: During Q4 2025, Shiloh’s general purchasing policy will be updated to consider the requirements included in 2 CFR 200.328 through 200.326. (Note: This update was originally to be implemented in Q4 2024 but was delayed due to unexpected turnover in the Business Department.)

Written procedures and conflict of interest policies in accordance with the Uniform Guidance will be established and implemented during the year ended June 30, 2026.

COVID-19 - Coronavirus State and Local Relief Funds (CSLRF)-Assistance Listing No. 21.027 Procurement Recommendation: The Town should review and enhance controls and procedures to ensure that it follows the established procurement policy for all goods and services charged to the program and should ensure that all departments are subject to applicable controls, policies and procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will implement procurement processes for goods or services exceeding $10,000 to ensure vendors are selected in a manner providing full and open competition where property or services are being acquired under a Federal award. Name(s) of the contact person(s) responsible for corrective action: Lewis George, Town Administrator Planned completion date for corrective action plan: 01/01/2026

Methodist recognizes the current gap between Supply Chain Services and the Research Institute related to retaining documents for procurement activities. Supply Chain Services will develop processes to retain written documentation for procurement activities in accordance with regulatory standards. As Methodist is in transition to a new ERP system in Quarter 1, 2026, Supply Chain Services will include strategies to address the needs in both the short term and long term.

2024-002 Finding Subject: COVID 19: Coronavirus State and Local Fiscal Recovery Funds - IFA Grant - White Ditch– Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources. Description of Corrective Action Plan: All purchases need to be made in accordance with the Sanitary District of Michigan City Purchasing Policy. All contracts will be supported by a written and signed contract document per Section 9.0 of the Sanitary District of Michigan City Purchasing Policy. Suspension and Debarment 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Description of Corrective Action Plan For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025

FINDING 2024-001 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources Description of Corrective Action Plan: All purchases need to be made in accordance with the City of Michigan City Purchasing Policy. Purchases made under the Special Purchase provision (I.C.5-22-10-1) will abide by section 7.4 of the Michigan City Purchasing Policy. This section describes the required record keeping. Suspension and Debarment Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.320 states in part: (a) "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . Description of Corrective Action Plan: For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025 INDIANA STATE

Federal Award Findings Finding 2024-003 U.S. Department of Treasury Passed through State of South Dakota Board of Water and Natural Resources Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The City does not have a formal documented procurement policy which includes written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts with federal funds . Responsible Individuals: Mike Steen, Mayor and Amanda Metzinger, Finance Officer Corrective Action Plan: Management plans to formally document and approve an official written procurement policy that follows all necessary state and federal laws, including the required procurement standards within 2 CFR sections 200.318 through 200.327. Anticipated Completion Date: 9/22/25

FINDING 2024-004 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately, which will include implementing a federal procurement policy. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Anticipated Completion Date: August 30, 2025

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