Corrective Action Plans

Corrective Action Plan Contact Person(s): Janet Carbary, Deana Gilpin Management agrees with this finding and recognizes the need to strengthen internal controls over purchasing processes to ensure compliance with Uniform Guidance requirements (§200.317–§200.326; §200.213). To address the deficiency, the Organization will implement the following actions: 1. Update Purchasing Policies and Procedures o Purchasing policies will be revised to clearly incorporate Uniform Guidance requirements, including competitive bidding thresholds, procurement method selection, and documentation standards. o Policies will explicitly require verification of suspension and debarment status for all vendors receiving federal funds. 2. Implement Mandatory Suspension and Debarment Verification o Staff will be required to document verification through SAM.gov or other approved sources before awarding or renewing contracts funded by federal awards. o A verification will be maintained and reviewed by Finance leadership. 3. Enhance Procurement Documentation Controls o Leadership will ensure all federal purchases meet the requirement below before purchase approval. • Competitive purchasing requirements are met • Cost/price analyses are documented when required • Suspension/debarment verifications are completed and retained 4. Training for Finance Staff o Staff involved in purchasing, contract approval, and grant management will receive training on Uniform Guidance procurement rules and suspension/debarment requirements. 5. Periodic Internal Monitoring o Revenue accountant will monitor expenses related to federal programs monthly to ensure compliance. o Senior management will be notified if corrective steps are needed. Anticipated Completion Date: December 31, 2025 Responsible Officials: • Chief Financial Officer (CFO) • Accounting Manager • Director of Financial Planning

Procurement Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplified acquisition method of procurement. Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges that even though grant objectives were met, procurement procedures must be followed regardless of timeline constraints. Management has implemented enhanced controls to ensure compliance with internal procurement policies, including: (1) mandatory documentation for simplified acquisitions requiring evidence of price reasonableness; (2) staff meetings on procurement requirements; and (3) supervisory review of procurement files prior to grant invoice submission. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025

The District will develop and implement a formal procurement checklist. This checklist will be completed by the Business Manager for all purchases expected to exceed the micro-puchase threshold. The procedure will require the checklist to be completed and attached to the purchase order before the purchase is finalized, ensuring and documenting that the required price of rate quotations have been obtained in accordance with 2 CFR section 200.320.

The District Cafeteria Manager, Melanie Pardini, corrected this procedure for fiscal year 2025-26 and has the process in place going forward for each fiscal year.

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

There is no disagreement with the finding. Management will review policies in alignment with minimum Uniform Grant Guidance procurement thresholds and District documentation of internal controls related to policy.

OBI will update current purchasing and procurement policy to specifically address the acquisition of property or services using federal grant funds to ensure adherence to Federal procurement standards in 2 CFR Part 200 sections 200.317-200.327. Our policy will outline requirements regarding vendor selection and vendor qualification. It will address the simplified acquisition threshold, micro purchases threshold, and the formal procurement methods that must be adhered to when the value exceeds those thresholds. The policy will include when sealed bids, proposals/requests for proposals are required and when sole source procurement is appropriate and allowable. Whenever sole source procurement is used, the rationale will be documented and approved. Our policy will include language requiring that all vendors and contractors paid using federal funds be checked for federal suspension & debarment using Sam.gov. Vendors found on the exclusion list will not be paid using federal funds. The policy outlines requirements for written approvals and documentation of all procurements. Additionally, OBI has implemented procedures to ensure that at the point of receiving the Notice of Award, any federal money or grant awarded to OBI will be immediately communicated to the CFO, Controller, and the Senior Accountant. Person(s) Responsible: Senior Accountant with review and approvals from Controller and CFO Estimated Completion Date: January 31, 2026

CONTACT PERSON: Matt Pettit, Chief Financial Officer, matthew.pettit@cherokee1.org CORRECTIVE ACTION: The District will ensure that it does not use local exemptions for any federal programs. PROPOSED COMPLETION DATE: Prior to June 30, 2026

CONTACT PERSON: Matt Owens, Chief Financial Officer, mattowens@pickens.k12.sc.us CORRECTIVE ACTION: The District has implemented procedures to ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. PROPOSED COMPLETION DATE: Prior to June 30, 2026

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

Finding: 2025-001: Procurement Noncompliance - Child Nutrition Cluster. Contact Person: Lisa Hammerly, Director of Business Services. Recommendation: The District should continue to implement and monitor updated procurement procedures, including use of centralized tracking, pre-approval of purchases, and adherence to formal solicitation processes. Corrective Action: The District agrees with the finding. Corrective action was initiated in April 2025, including adoption of revised procurement procedures, implementation of monitored tracking, and initiation of a formal bid process for recurring food purchases. Proposed Completion Date: Policy revision completed March 2025, staff training completed April 2025, monthly monitoring effective beginning May 2025.

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micropurchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Small Purchase Procurement: We have enhanced document retention procedures around small purchase procurement including staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure a minimum of 3 bids/quotes are obtained on any grant-funded purchases or services greater than $10k. We will be utilizing NetSuite's Document Library to manage document retention for grant-related bids and quotes. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

CHA currently has a general procurement plan in place to guide its purchasing and contracting activities. However, to ensure full compliance with federal regulations, CHA will be updating its existing procurement policy to align with the Uniform Guidance requirements. This update will formalize procedures related to vendor selection, competitive bidding, and documentation to maintain transparency, accountability, and consistency across all procurement processes.

Management accepts the recommendation and will ensure compliance with the procurement standards in 2 CFR §§ 200.318–200.327 for all federally funded purchases by either conducting a competitive bidding process or documenting and obtaining approval for a sole source procurement as allowed under 2CFR §200.320(c)

Internal Controls over Compliance and Compliance with Procurement Standards Individual Responsible for Corrective Action Plan: Christopher Holleman, Interim CFO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Management will ensure that the policy be redistributed for retraining purposes underscoring the vital importance of following the policy and federal guidelines related to procurements. In addition, the CFO will take lead to ensure that the procurement policy is appropriately applied, and documentation meets required standards.

Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants. Name(s) of the contact person(s) responsible for corrective action: Jason Jerome Planned completion date for corrective action plan: December 31, 2025

The Village will ensure that proposals be submitted for architectural and engineering professional services, and that documentation will be maintained for the proposals obtained as well as the Village’s determination of the most qualified vendor.

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Below $50k there will also be formal procedures with increasingly more oversight for purchases as they increase in cost. We will form and document a detailed procedure for issuing RFPs for PO amounts over $50k. We will review at least 3 proposals and once one is chosen, the vendor will be vetted before the proposal is accepted.

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

FINDING 2024-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: K. Rochelle Seneff Contact Phone Number and Email Address: (812)649-2242 ct@rockportin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement As Clerk-Treasurer, I will educate all parties involved on the requirements that were found to be unfulfilled through this Federal Audit. For the duration of any federally funded projects, a discussion will be held during a public board meeting, detailing the rationale behind the City's decision to work with the vendors selected for small purchases and simplified acquisitions. This will be done to verify that all vendors, even when bids are not required, were retained through appropriate methods. A procurement policy that outlines the City's procedures and conforms to applicable federal, state, and local laws will be developed and taken to the Common Council for approval. Suspension and Debarment All vendors who participate in the project will receive a Suspension and Debarment Certificate provided by the City that must be signed by a representative of the vendor and filed with the vendor's contract or in the project folder. Anticipated Completion Date: December 23, 2025

Condition: The organization intended to use a competitive proposal process to procure a van. However, it failed to publicly advertise the request for proposals, limiting the pool of potential vendors to only those known to the organization. Additionally, the request for proposals did not include a complete and accurate list of specifications, nor did it include the evaluation and selection criteria that would be used to assess the proposals. While the organization did obtain three proposals and documented its rationale for selecting a vendor that was not the lowest bidder, the overall process did not meet the standards for full and open competition required by federal regulations. Corrective Action Plan: To address this, we are committing to develop and implement a comprehensive procurement policy and procedures manual that strictly aligns with requirements within the Uniform Guidance. This manual will include detailed checklists for all procurement methods, covering public advertising, clear specification development, and the use of pre-established, documented evaluation criteria, followed by mandatory training for all staff involved in procurement. Responsible Party: Austin Maddox, CFO Anticipated Completion Date: December 31, 2025

The District will ensure that there are at least 2 quotes obtained for any purchase over the $10,000 threshold using federal monies. The District will also verify that the vendor being used is not suspended or debarred by checking the SAM exclusions and requiring the vendor to provide a certificate of verification.

Management is not in agreement with this finding. We have a policy in place to ensure that all purchases above the micro purchase threshold needs to be supported with competitive bids. Senior management was not informed in time to produce the necessary documentation to the auditors. To ensure compliance in the future, management has revised its formal policy manual to include a formal checklist before signing any commitments that competitive bids have been obtained.

Management Response/Corrective Action Plan: Prior to any purchase orders being issued, we will ensure that bidding procedures have taken place and that SAM.gov has been reviewed and documentation is attached.

Finding 2024-004 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement Questioned Programs ALN 15.022 Tribal Self Governance Agencies: Department of Interior Award Numbers GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Condition The Association is not consistently following their own internal control policy for purchases that meet their small purchase threshold for procurement to obtain price or rate quotations from an adequate number of qualified sources. Status In Progress Management’s Corrective Action Plan Thorough training in AVCP’s procurement policies and procedures has been performed within this department. AVCP also held an overall training of AVCP’s key and senior personnel by an outside expert in government procurement rules and regulations.