Corrective Action Plans

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Stan Heil Contact Phone Number and Email Address: 812-542-0506-sheil@floydcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Floyd County has concurred with the material weakness finding and has accepted the recommendation provided of “we recommend that management of the County establish a proper system of internal controls and develop procedures to ensure that property and services are properly procured and that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards.” Floyd County will present all appropriate Requests for Proposal to the Commissioners for approval, publish in local arenas as required by statute, receive bids by defined deadlines, present to Commissioners for opening in a public setting, take under review with the County Attorney, and award according to statute timely. Dept of Treasury-Covid 19 funds, were paper files out for scanning and the County was unable to retrieve the specifics to support all needed functions requested during the Audit period. Documentation of past and future actions will be maintained in electronic retrievable format. All actions recommended and produced in this Corrective Action Plan have been, and will be adhered to for transparency, efficiency, and ethically. Anticipated Completion Date: The anticipated completion date of the Corrective Action Plan identified above will occur September 30, 2026 reporting as the exposure of this finding-weakness, is being addressed.

2025-003 Under 2 CFR §200.318-326, non-federal entities must adhere to procurement standards for purchases made with federal funds. Key requirements include: - Full and Open Competition: Procurement transactions must be conducted to ensure open competition and prevent practices that may unduly restrict competition (2 CFR §200.319(a)). - Documentation of Procurement History: Entities must maintain records that detail the procurement history, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR §200.318(i)). - Use of Non-Competitive Procurement: Non-competitive procurement is only allowed under limited circumstances, such as when the item is available from a single source, there is a public emergency, or after solicitation of multiple sources, competition is deemed inadequate (2 CFR §200.320(c)). Recommendation: Implement comprehensive procurement policies and procedures that comply with federal regulations under 2 CFR §200.318-326. Ensure all procurement transactions are documented, including evidence of competitive bidding or justification for noncompetitive procurement under 2 CFR §200.320(c). Conduct staff training on procurement standards for federal awards, focusing on documentation, competition, and conflict of interest requirements. Perform periodic internal reviews to confirm compliance with procurement policies. Consult with California’s HCD regarding their expectations of contractor selection policies for the HomeKey program. Management Response: Management concurs with the recommendation and recognizes that procurement compliance requires both appropriate competition and sufficient contemporaneous documentation demonstrating how the procurement decision was made. HTM will strengthen its procurement framework to ensure applicable procurement requirements are identified before purchases are initiated and that the procurement file demonstrates the method used, competition obtained, selection rationale, required approvals, conflicts review, price or cost considerations where applicable, and justification for exceptions. Corrective Action Status and Plan: Management adopted a procurement policy July 2026 and plans to implement supporting procedures designed to comply with applicable federal, state, local, and award-specific requirements. By December 31, 2026, the Mission plans to issue detailed procedures and standardized procurement-file templates covering procurement method selection, applicable thresholds, independent cost or price analysis, full and open competition, solicitation and bid documentation, conflict-of-interest disclosures, contractor selection or rejection, contract type, price basis, required approvals, and permitted noncompetitive procurement justifications. Vendor onboarding will require documented suspension and debarment verification for each applicable vendor and contractor before commitment of funds, with evidence retained in the procurement file. Staff with purchasing, program, grant, and accounts-payable responsibilities will complete rolebased training, and completion records will be retained. Management plans to consult with California HCD regarding contractor-selection expectations for the HomeKey program and incorporate applicable requirements into the policy, procedures, and contract summaries. The Chief Financial Officer or designee will conduct and document periodic samplebased compliance reviews, track exceptions to resolution, and report material or recurring issues to executive management. Management plans to complete an operating-effectiveness review of procurement transactions and address identified deficiencies before year-end. Management also plans to implement a broader grant and contract compliance framework, as described in Finding 2025- 002, to establish responsibility for identifying, communicating, and monitoring compliance requirements associated with government funding agreements. Although a procurement policy was adopted in 2026, it was not fully operational during the audit period. Procedures to verify and document compliance with suspension and debarment requirements were also not consistently performed. As a result, compliance requirements associated with government-funded programs were not fully executed and documented during the year. These corrective actions will strengthen compliance with procurement regulations and suspension and debarment requirements, improve documentation and monitoring controls, and reduce the risk of future noncompliance with government funding requirements. Name of responsible persons: Emily Falappino, VP of Business Affairs, Ivet Samvelyan, VP of Mission and Impact and Tisha Lazare, Chief Financial Officer Anticipated completion date. December 31, 2026

The Commissioner’s office will consult with legal counsel to update polices to meet requirements of 2 CFR 200.

FINDING 2025-018 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Vendor Setup & Conflict Verification: Standardized new vendor onboarding under the Purchasing Director. Requires W-9s, registration forms, annual SAM.gov suspension/debarment checks, state business registration checks, and local property tax searches to rule out employee/board conflicts of interest. Multi-Phase Procurement Overhaul: • Phase 1 (2025–2026): Established board-approval workflows for all contracts, quotes, and invoices. • Phase 2 (2025–2027): Enforced proper quote, bid, and special purchasing compliance. • Phase 3 (2026–2027): Updating board policies and internal controls to enforce federal uniform purchasing guidelines. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

FINDING 2025-013 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Enforced updated Internal Controls Manual purchasing thresholds and pre-approval workflows. Executing a multi-step resolution: board approval workflows established in 2025–2026, proper procurement/bidding compliance expanded through 2026–2027, and updating board policy to enforce uniform federal guidelines in 2026–2027. Anticipated Completion Date: June 30, 2027

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

Finding Number: 2025-004 Finding Title: Procurement Program: 16.710 Public Safety Partnership and Community Policing Grants Name of Contact Person Responsible for Corrective Action: Daniel Palmer, Deputy Director, Emergency Communications Corrective Action Planned: Upon review, we determined that program staff did not confirm with Purchasing and Contracting at the county that the contract was acceptable under our procurement policies which would have caught the error. Three generators were purchased under this contract, and the total cost was significantly below the expected and budgeted amount. To prevent this issue from occurring in the future, Ramsey County is implementing the following corrective action: • If the COPS Office determines that the $273,011 purchase of generators needs to be refunded, Ramsey County is prepared to submit a Grant Award Modification (GAM) requesting to use those funds to purchase additional needed radios for Emergency Communications and Corrections. • Enhanced training: We will provide regular training for departments to cover procurement policies and internal review processes at the department level. Anticipated Completion Date: December 31, 2026

Corrective Action Plan for the Calendar Year Ended December 31, 2025 In response to the finding from the Federal Single Audit for the fiscal year ended December 31, 2025. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2025-002- Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will continue to strengthen its processes and internal controls to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained. Christopher Caulfield, Assistant Vice President of Finance, will effectuate the corrective action plan, which will be completed by December 31, 2026. 973-754-2016

FINDING 2025-003 Finding Subject: Drinking Water State Revolving Fund – Procurement Contact Person Responsible for Corrective Action: Beth Stocking, Clerk-Treasurer Contact Phone Number and Email Address: 574-223-2510 clerk@rochester.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City concurs with the finding. The City will adopt and use written procurement procedures for purchases made with federal award funds that incorporate applicable 2 CFR Part 200 requirements and the terms of each federal award. Before a purchase or contract is initiated, the City will identify whether federal funds are involved and determine the required procurement method based on the applicable threshold and type of procurement. The City will use required competitive procedures, public advertising, and formal procurement methods when applicable. Architectural and engineering professional services will follow applicable qualifications-based competitive proposal requirements. Any permitted noncompetitive procurement will include documented justification. Procurement files will retain solicitations, quotations or proposals, evaluations, approvals, contracts, and documentation supporting the method and selection. The Clerk-Treasurer will coordinate review of federal procurement requirements with the responsible department and professional advisors before federally funded contracts are executed, and personnel involved in federal awards will be instructed on the procedures. Anticipated Completion Date: December 31, 2026, with the procedures to be applied immediately to new procurements involving federal award funds.

In 2026, procedures to ensure that future procurements associated with Federal awards comply with applicable Federal procurement requirements were developed, documented, and implemented. These procedures include requirements for public solicitation and full and open competition when applicable, as well as review of existing contracts before they are used for Federal award activities. The Organization will maintain appropriate documentation demonstrating compliance with applicable Federal procurement requirements.

Description of Corrective Action Plan: For any future projects funded with federal money, the City will ensure the federal procurement standards are followed. Anticipated Completion Date: Immediately, will be considered for any future procurements done with federal funds.

Finding Number: 2025-003 Finding Title: Procurement, Suspension, and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Tiffany Bailey – Fiscal Manager Corrective Action Planned: The planned corrective action is to improve and update the agency policy and procedures for procurement and implement a process with supporting documentation that ensures federal requirements are met. Anticipated Completion Date: December 31, 2026

See the Corrective action plant for chart/table

Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors' concerns regarding the retention and availability of historical procurement documentation. However, SWK notes that this finding relates primarily to documentation retention and retrieval rather than a failure to perform procurement activities or suspension and debarment verification. The primary issue resulted from the termination of the Unaccompanied Alien Children (UAC) Program during Fiscal Year 2025, which led to significant organizational downsizing, including the elimination of the Procurement Department. Historical procurement, solicitation, and bid documentation had been maintained within a procurement software platform administered by that department. Following program closure and the departure of procurement personnel, the software platform was decommissioned, resulting in certain historical procurement records no longer being readily accessible during the audit. SWK did, however, provide evidence that vendors selected for procurement actions were screened for suspension and debarment in accordance with federal requirements. Additionally, two of the six contracts exceeding the simplified acquisition threshold represented renewals of previously procured contracts; however, complete historical bid files could not be retrieved for audit review. SWK further notes that as of the date of this corrective action plan: • The UAC Program has been terminated. • SWK no longer maintains a dedicated Procurement Department. • SWK has no active federal procurement contracts over $250,000 requiring formal solicitation procedures. • No questioned costs were identified by the auditors. • The auditors concluded that services and goods purchased under the reviewed contracts were allowable and supported program operations. Corrective Actions Although the circumstances surrounding this finding relate to historical records associated with a discontinued program, SWK has implemented the following actions to strengthen document retention and procurement oversight for any future federally funded procurements: 1. Centralized Procurement Record Retention SWK has established a requirement that all procurement-related documentation, including solicitations, bid responses, evaluations, vendor selection justifications, contract approvals, and suspension/debarment verifications, be maintained in a centralized electronic repository controlled by Finance and Administration, rather than an individual department or software administrator. 2. Procurement Documentation Checklist SWK will continue to utilize a standardized procurement checklist for any future procurement transactions subject to federal procurement requirements. The checklist will ensure required documentation is retained and readily accessible for monitoring or audit purposes. 3. Enhanced Document Archiving Procedures Prior to the discontinuation of any program, department, or software platform, SWK will perform a records-retention review to ensure all procurement and contract documentation subject to federal record retention requirements is archived and preserved. 4. Management Oversight The Chief Administrative Officer will be responsible for periodic reviews of procurement files to verify that required documentation is complete and retained in accordance with federal and organizational requirements. 5. Future Procurements SWK will review and update its documented procurement procedures to conform to applicable federal statutes, the procurement requirements identified in 2 CFR Part 200, and the new federal procurement thresholds as of October 1, 2025. Further, SWK will institute a centralized purchasing function under Finance and Administration to facilitate the review of procurements to ensure compliance with both 2 CFR Part 200 and the terms and conditions of awards. This function will ensure the enforcement of the procedures mentioned above by: - Conducting vetted vendor onboarding and ongoing management via periodic reviews to verify that non-federal entities, contracts, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federal programs - Obtaining appropriate documentation of multiple vendor quotes and/or sole source justification for small purchases greater than the micro-purchase threshold, but below the simplified acquisition threshold - Managing, following, and documenting the simplified acquisition procedures for purchases greater than or equal to the simplified acquisition threshold Expected Completion Date: In process and to be completed by December 31, 2026 Ongoing monitoring and compliance reviews will continue for any future procurement activities. Status Corrective action substantially implemented. Upon review of current FY2026 purchases and due to the closure of the UAC Program, the risk associated with this finding has been significantly reduced. The corrective actions above are designed to ensure appropriate documentation retention and compliance should future federally funded procurement activities occur. Responsible Officials: Chief Administrative Officer, Marisol Cervera

Finding 2025-005: Noncompliance over Procurement Name of Contact: Chris Pallister, Executive Director Corrective Action: Management will establish and maintain written procurement procedures as specified in the Uniform Guidance procurement standards. For purchases and contracts exceeding $50,000 annually the Organization will publish RFP’s on SAM.gov at least 60 days prior to the project start date. The RFP’s will include the following aspects: • Scope of Work (SOW) or Performance Work Statement (PWS): The RFP should clearly define the project objectives, tasks, and expected deliverables. • Instructions to Bidders: Detail how proposals must be formatted, page limits, and precise submission directions. • Evaluation Criteria: State how bids will be scored (e.g., technical approach, past performance, and price weighting). • Federal Provisions: Include required federal clauses (such as Buy American requirements or Uniform Guidance standards. Any proposals received in response to the RFP will be considered. Proposed Completion Date: November 15, 2026.

Finding 2025-006 I. Procurement, Suspension and Debarment Procurement Approval and Executed Agreement Compliance Management agrees with the finding and has outlined the following corrective actions: • Obtain Board approval for a new intergovernmental agreement for Chicago Police Department at the September 2026 board meeting. • Complete a full review of 2025 and 2026 procurement files by the end of Q1-2027 to ensure all required Board approvals and executed agreements are retained. • Strengthen internal workflows to prevent procurement actions from proceeding without verified approvals and executed agreements through inclusion of a new checklist which will be reflected in an updated standard operating procedures (SOP). • Provide refresher training to procurement staff on 2 CFR 200 documentation retention requirements by December 2026. Suspension and Debarment Compliance Management concurs with the findings and will implement: • Semiannual targeted training to reinforce staff responsibilities for verifying vendor eligibility and documenting compliance to begin December 2026. • Enhanced managerial monitoring through a standardized checklist to ensure required suspension/debarment checks are completed and retained before issuing purchase orders. Implemented January 2027. Responsible for Corrective Action: Tamika Carson, Director of Procurement; Sheila Johnson, Deputy Chief Procurement Anticipated Completion Date: Q1-2027

Community Project Funding / Congressionally Directed Spending – Assistance Listing No. 17.289 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Assistance Listing No. 10.561 Recommendation: We recommend management revise procurement policies to fully align with Uniform Guidance requirements and strengthen procedures to ensure procurement decisions, management approvals, competitive procurement documentation, and suspension and debarment verifications are consistently performed, documented, and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed and updated the financial policies and Procedures Manual as of 01/2026. Procurement procedures have been strengthened. Federal procurement documentation requirements have been incorporated into our process. Suspension and debarment reviews are now being conducted and documented for all new vendors. Procurement files now include approval and compliance documentation. Name(s) of the contact person(s) responsible for corrective action: Stacia Russell Planned completion date for corrective action plan: 01/01/2026

Management Response: Management has reviewed Finding 2025-001 and concurs with the auditor’s observations. Management recognizes that the exceptions resulted from incomplete procurement documentation and inconsistent use of the required Federal contract provisions and procurement file checklists. Context and corrective actions: • The omission of the Federal contract provisions required by Appendix II to 2 CFR Part 200 was identified through monitoring performed by the grant administrator on behalf of the pass-through entity. Management initiated remediation during the audit period and has amended the affected contracts to include the applicable provisions. Management will also complete a review of active federally funded contracts by September 30, 2026, to confirm that required provisions are included. • One contract lacked documentation demonstrating that the procurement was conducted in a manner providing full and open competition. The vendor relationship predated the grant award; however, management acknowledges that the existing relationship did not, by itself, demonstrate compliance with the applicable procurement documentation requirements. For future federally funded procurements, including procurements involving existing vendors, management will retain documentation of the procurement method, competition performed, and supporting rationale. • For future procurements, the procurement file must include documented evidence of the required price or cost analysis and suspension and debarment verification before contract award or renewal. These requirements will be incorporated into a standardized Federal procurement checklist, as outlined below, with documented review and approval by the Director of Finance and COO. • Management will provide procurement compliance training to relevant personnel by September 10, 2026 and will perform periodic monitoring of federally funded procurement files. Monitoring results will be reported to Board of Directors, and identified exceptions will be tracked through resolution. • The seven exceptions involved four contracts valued below $50,000, two contracts valued between $50,000 and $100,000, and one contract valued above $100,000. These amounts provide context regarding the potential dollar magnitude of the exceptions but do not change management’s obligation to maintain complete procurement documentation and comply with applicable Federal requirements. • Based on the auditor’s procedures, no questioned costs resulted from this finding, and the costs tested were allowable under the grant and otherwise properly supported. Management nevertheless recognizes the importance of addressing the procurement documentation gaps and believes the corrective actions described above will strengthen compliance, improve oversight, and reduce the risk of recurrence. • Management will Develop and Implement Comprehensive Federal Procurement Compliance Checklist. o The Organization has developed a single, comprehensive Federal Procurement Compliance Checklist to be completed for all covered procurements. This checklist ensures compliance with 2 CFR Part 200 (Uniform Guidance) across all identified deficiency areas. The checklist includes: o Federal Contracts Provisions Section (including all contract provisions required by Appendix II to 2 CFR Part 200) o Full and Open Competition Section (including threshold determination, type of procurement method, evidence of public posting, responses, and evaluation of vendors, or a documented Sole Source procurement approval) o Price/Cost Analysis Section (including analysis method, documentation analysis was performed, and evaluation that proposed cost is reasonable). o Suspension and Debarment Verification Section: documented SAM.gov database search, and documentation of escalation if a vendor is found to be on the exclusion list. o The checklist will be integrated into standard procurement workflows to ensure automatic compliance. o Completed checklist must be signed off by the Director of Finance and COO. All documentation referenced in the checklist (competition records, cost analysis, debarment verification) must be retained with the procurement file. o Organization finalized the comprehensive checklist by August 31, 2026 and provided training to all procurement staff by September 10, 2026. The checklist will be required for all new procurements effective September 1, 2026. For all contracts entered into prior to September 1, 2026 that did not comply with the provisions in Appendix II to 2 CFR Part 200, the organization will complete retroactive documentation to the extent possible and execute amendments to incorporate missing Federal provisions by September 30, 2026. Anticipated Completion Date: August 31, 2026 (checklist development); September 30, 2026 (retroactive compliance and amendments) Responsible Party: Daniel Wilmot, Director of Finance

Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importance of complying with its purchasing and procurement policies.

Condition: A competitive procurement process was not performed for one vendor selected for testing. Corrective Action Planned: 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 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 Office 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 Office to ensure ongoing compliance. Anticipated Completion Date: Implemented March 1, 2026 Contact: Nancy J. Konisky, Business Manager

BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026

Management acknowledges that procurement documentation was not consistently maintained during the audit period. Because the FY2024 audit was completed after the FY2025 fiscal year had ended, management did not have an opportunity to implement the prior-year corrective actions in time to affect the FY2025 audit period. Since the audit period, the Organization has strengthened procurement and compliance oversight by elevating the Director of Programs position to Vice President of Programs in September 2025, launching the Compliance and Risk Management Committee in FY2026, and creating a Compliance & Evaluation Manager position with an anticipated start date in August 2026. Fiscal and program leadership have substantially revised the procurement policy and are developing related procedures and standardized documentation requirements. The policy and procedures will be reviewed by the Compliance and Risk Management Committee in early FY2027 before being submitted for Board approval. The revised materials address competitive quotations and bids, vendor selection, price reasonableness, noncompetitive procurement justifications, conflict-of-interest requirements, debarment verification, and documentation of the procurement history. The FY2027 budget includes 2 CFR Part 200 training for Fiscal, Programs, and Grants staff. Blackbaud Financial Edge, scheduled to go live in FY2027, will further support approval workflows, transaction tracking, role-based access, and document retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken • Elevated the Director of Programs position to Vice President of Programs in September 2025. • Launched the Compliance and Risk Management Committee in FY2026. • Created a Compliance & Evaluation Manager position, with an anticipated start date in August 2026. • Strengthened supervisory review and reinforced procurement documentation expectations. • Substantially revised the procurement policy and began developing standardized procedures and documentation requirements. • Scheduled Compliance and Risk Management Committee review of the revised policy and procedures for the fall of 2026. • Included 2 CFR Part 200 training for Fiscal, Programs, and Grants staff in the FY2027 budget. • Initiated implementation of Blackbaud Financial Edge; planned go-live for October 2026.

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE

Lima City Schools has procurement policies and procedures in place and will ensure that all contracts entered into for purchased services will be sure to follow the board approved procurement policies and procedures. The Lima City Schools will establish appropriate controls to ensure there is no overpayment. The board will obtain appropriate price quotes and non-competitive proposals and verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.