Corrective Action Plans

2026-004 Procurement Corrective action planned: OMC will follow its current procurement policy and will seek bids for contracts with autorenewals, utilities, and professional services. However, OMC will also review its current procurement policy to see if changes are necessary to reflect the current environment to exclude items such as certain utilities and services from the bid process if such utilities and services are unique and limited to the service area of the health center and if only one option exists or the current vendor is performing sufficiently so that undue burden would be placed on the Organization to switch vendors, then a sole source justification will be documented, in both paper format and electronically so that records are readily available for review. Anticipated completion date: 08/31/2026 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

FA 2025-003 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $333,778 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 the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The School District concurs with the finding and will strengthen internal controls to ensure that all expenditures charged to the Child Nutrition Cluster comply with applicable federal procurement and suspension and debarment requirements. • Review and update procurement procedures for federally funded Child Nutrition purchases to ensure compliance with federal, state, and District requirements. • Require documentation of suspension and debarment verification for applicable vendors prior to purchases using federal funds. • Implement a federal procurement checklist to document required quotes, approvals, procurement methods, and vendor eligibility verification. • Provide training to Finance, Purchasing, and Child Nutrition personnel on federal procurement and suspension/debarment requirements. • Conduct periodic reviews of Child Nutrition expenditures to verify that procurement and vendor verification requirements are being followed and properly documented. Estimated Completion Date: June 30, 2027 Contact Person: Kimberly Harrison Telephone: 912-427-1000 Email: kharrison@wayne.k12.ga.us

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 84.027A - Special Education Grants to States 84.173A – Special Education Preschool Grants H027A240073 (Year: 2025), H027A230073 (Year: 2024) H173A240081 (Year: 2025), H173A230081 (Year: 2024) $11,583 Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The School District will strengthen internal controls to ensure that all expenditures charged to the Special Education Cluster (as well as other federal program clusters) comply with applicable federal procurement and suspension and debarment requirements. • Review and update procurement procedures for federally funded purchases to ensure compliance with federal and District requirements. • Require documentation of suspension and debarment verification for applicable vendors prior to purchases using federal funds. • Implement a procurement checklist or verification spreadsheet and process for federal purchases to document required quotes, approvals, procurement methods, and suspension/debarment verification. • Provide training to Finance, Purchasing, and applicable school/district personnel on federal procurement and suspension/debarment requirements. • Conduct periodic reviews of federal expenditures to verify that procurement documentation and vendor eligibility checks are completed and maintained. Estimated Completion Date: June 30, 2027 Contact Person: Kimberly Harrison Telephone: 912-427-1000 Email: kharrison@wayne.k12.ga.us

Corrective action planned – Management recognizes that procurement is a material concern of the organization both from an operational efficiency and regulatory compliance perspective. During the audited time period, procurement responsibilities were decentralized, resulting in inconsistent compliance. In April 2025, Management decided to create a dedicated Procurement Department and began staffing the department. The new Procurement team is tasked with reviewing all current procurement policies and procedures, revising and creating new processes as needed, and partnering with the compliance team to monitor compliance going forward. The policy and procedure revisions will be implemented by the end of the fourth quarter of 2025. Staff will receive training by the first quarter of 2026, and after the training rollout, we will begin internal audits to ensure successful training, implementation and compliance with the new policies and procedures. Name(s) of contact person(s) responsible for corrective action – Richard Sroka, Senior Fiscal Program Analyst in charge of grant reporting Anticipated completion date – November 2026

Finding No.: 2025-007 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Federal Award No.: H027A230013, H027A240013 Area: Procurement and Suspension and Debarment Questioned Costs: $538,090 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding procurement and suspension and debarment requirements. GDOE recognizes the need to strengthen procurement procedures to ensure the appropriate procurement method is selected required documentation is maintained, and applicable contract modifications are properly supported. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement activities should be planned and reviewed sufficiently in advance to ensure that the appropriate procurement method is selected required approvals and documentation are completed, and services are not initiated before the procurement is properly executed. The GDOE Supply Management Office will: 1. Review and update procurement procedures to address applicable federal procurement requirements, including procurement methods, documentation, and contract modifications. 2. Establish procedures to evaluate similar or related services when determining the appropriate procurement method, regardless of funding source. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to monitor compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will verify compliance with procurement requirements and completion and documentation of suspension and debarment verifications.

Finding 2025-06 Procurement and Suspension and Debarment: Inadequate Documentation of Competitive Bidding Procedures – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Planned Corrective Action Plan: APU will strengthen its procurement procedures to require retention of documentation supporting the procurement method used, solicitations, bids or proposals received, evaluation of responses, vendor selection, and the basis for the procurement decision when competitive procurement requirements apply. Procurement documentation will be retained in a centralized procurement file.; Anticipated Completion Date: July 1, 2027

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

Enhanced Mobility of Seniors and Individuals with Disabilities – Assistance Listing No. 20.513 Recommendation: Management at Sound Generations should review its existing control structure and ensure that there are adequate processes and controls to ensure the correct procurement methods are used and that documentation of quotes, bids, vendor evaluations, and price analysis is appropriately maintained. Sound Generations should follow its policies and procedures and ensure suspension and debarment checks are performed on a timely basis for all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Sound Generations converted to new software, and we have included a field for SAM.gov compliance and as part of our new vendor approval require a screen shot of the SAM.gov validation. Name(s) of the contact person(s) responsible for corrective action: Kristina Morgan, Controller, at 206-445-5671. Planned completion date for corrective action plan: June 2026.

View of Responsible Officials: Management acknowledges the finding and agrees that documentation supporting compliance with procurement requirements was not consistently retained. For the seven disbursements selected for testing, management had established longstanding relationships with the vendors utilized and, in several instances, there were a limited number of vendors capable of providing the specialized equipment and services acquired for the project. Management indicated that procurement procedures were performed during the vendor selection process, including obtaining and evaluating quotes, discussing vendor alternatives, and visiting other healthcare organizations to assess the quality and suitability of certain products before making purchasing decisions. However, many of these activities occurred several years earlier, at the outset of the construction project, and supporting documentation was not maintained in accordance with the Organization's procurement policy and federal documentation requirements. Management agrees with the finding and will implement procedures to ensure procurement activities are conducted and documented in accordance with the Organization's procurement policy and Uniform Guidance requirements. Corrective actions will include establishing a centralized procurement file, providing additional training to personnel responsible for purchasing activities, and implementing supervisory review procedures to ensure that competitive procurement and documentation requirements are consistently met and appropriately retained.

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

Identification of the Federal Program: Grantor: United States Department of Health and Human Services, Health Resources and Services Administration Program Name: Congressional Directives Assistance Listing No.: 93.493 Responsible officials: Joe Wilson, Koji Mabuchi Vice President Supply Chain, CPO, Sr. Director Corporate Compliance Phone: (914) 349-8701, (718) 920-6351 Email: joawilson@montefiore.org, kmabuchi@montefiore.org Projected completion date: March 30, 2027 Condition Title 2, Subtitle A, Chapter II, Part 200, Subpart D 200.320 – Procurement methods – requires entities to maintain documented procurement procedures and appropriate supporting documentation for procurement methods, including noncompetitive procurements. Purchases below the simple acquisition threshold, but above the micro-purchase threshold require price and rate quotations to be obtained from an adequate number of qualified sources. The Health System did not retain documentation demonstrating either (1) competitive bidding was performed or (2) the justification and circumstances supporting the use of a noncompetitive procurement method for equipment, installation and broadband services purchased under the grant. The procurement transactions reviewed exceeded the micro-purchase threshold; however, no supporting competitive procurement or sole-source documentation was available for audit inspection. In accordance with Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 - Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. The Health System has an established process to monitor vendor suspension and debarment requirements. Management’s process includes suspension and debarment evaluations on all new vendors prior to entering into any business relationship. The Health System utilized a third party to perform monthly suspension and debarment reviews; however, vendors associated with the program were not included in the listings provided to the third party for review. As a result, the Health System could not demonstrate that required suspension and debarment procedures had been performed for applicable vendors. Views of responsible officials and planned corrective actions Management agrees with the finding. The Health System has established procurement policies and procedures; however, the purchases identified in the audit were not consistently processed through the established procurement review process, and the required supporting documentation was not retained. The purchases involved IT equipment, installation, and broadband services necessary for the project. Management believes the vendor selections were supportable as sole-source procurements based on technical compatibility, integration with existing IT infrastructure, continuity of implementation and support, and specialized vendor capabilities. Management determined that the associated costs were allowable. Corrective action will focus on reinforcing departmental compliance with the existing procurement policy, requiring procurement’s involvement before vendor engagement, and ensuring that competitive bidding documentation or an approved sole-source justification is retained for all federally funded purchases. Although the Health System has an established suspension and debarment screening process, certain vendors associated with the Federal program were not included in the screening population. Management will implement a documented reconciliation of federally funded vendors to the screening population, including supervisory review and resolution of any exceptions, to ensure that all applicable vendors are screened and evidence of the screening is retained. No questioned costs were identified, and subsequent to the transaction management verified that none of the vendors tested were suspended or debarred at the time of the transactions.

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

Water and Sewer Department: The engineering services in question were procured through public advertisement for request of qualifications (enclosed). The RFQ evaluation process was followed and a selection was made. However, it appears that files were misplaced or discarded and we are unable to locate the RFQ evaluations or any other documentation to support the acquisition of the project engineer. Regarding the debarment and suspension regulations for Federal awards (2 CFR part 180), these requirements are typically included in the project bid specifications produced by the project engineer and become part of the project construction agreement. 2 CFR part 180 was inadvertently omitted from the project bid specifications including the construction agreement. In the future a more thorough review of the bid specifications will be conducted to ensure that all funding agency requirements are met. County Clerk of Courts: In response to material weakness identified as 2025-004, I was not the Clerk when this project was submitted to the Board in June of 2021. I attempted to locate any applicable documentation to support the project but was unsuccessful. I am aware of the need to obtain multiple quotes for projects and will do so in the future.

Reference: 2025-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus, Mayor; Adam Gitter, Interim City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2026

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.

FINDING 2025-004 Subject: Drinking Water State Revolving Fund - Internal Controls Federal Agency: Environmental Protection Agency Federal Program: Drinking Water State Revolving Fund (DWSRF) Assistance Listing Number: 66.468 Federal Award Numbers and Years (or Other Identifying Numbers): 2025 Pass-Through Entity: Indiana Financing Authority Compliance Requirement: Procurement Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the Town to ensure compliance with requirements related to the Drinking Water State Revolving Fund and Procurement compliance requirements as part of the Build America Buy America (BABA) requirement. Context: Crowe sampled two contracts that were subject to the procurement compliance requirements. Only one of the two contracts were subject to the Build America Buy America (BABA) requirements. Crowe noted that in that contract, management included contractual provisions addressing the American Iron and Steel requirements; however, the contract did not include provisions addressing the manufactured products and construction materials requirements applicable under BABA. As a result, the procurement control did not operate effectively to ensure that all applicable BABA requirements were incorporated into the respective contracts. Additionally, management was unable to provide sufficient supporting documentation demonstrating that construction materials used in the project were produced in the United States in accordance with applicable BABA requirements. Further, the documentation provided did not allow for a determination of the portion of total project costs attributable to construction materials as compared to iron and steel. Accordingly, Crowe was unable to determine whether the project complied with the applicable BABA requirements, resulting in a material weakness finding. Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Management will ensure their construction contracts include the BABA requirements, as applicable. Responsible Party and Timeline for Completion: The Town's Clerk-Treasurer will be responsible for implementing the corrective action plan, which will go into effect with future contracts that are entered into, as applicable.

FINDING 2025-003 Subject: Drinking Water State Revolving Fund - Internal Controls Federal Agency: Environmental Protection Agency Federal Program: Drinking Water State Revolving Fund (DWSRF) Assistance Listing Number: 66.468 Federal Award Numbers and Years (or Other Identifying Numbers): 2025 Pass-Through Entity: Indiana Financing Authority Compliance Requirement: Procurement Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the Town to ensure compliance with requirements related to the Drinking Water State Revolving Fund and Procurement compliance requirements as part of the small purchases procurement threshold. Context: One contract was subject to small purchase procurement testing for calendar year 2025. The Town disbursed $147,963 to DLZ, Inc. during 2025 for engineering services related to the new water treatment plant. Based on our testing, the Town did not obtain quotes or otherwise solicit proposals from other qualified engineering firms prior to procuring these services Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Town will enhance their internal controls process to ensure federal procurement guidelines are followed for future purchases based on the applicable thresholds. The procurement type will be documented and all related compliance requirements will be maintained. Responsible Party and Timeline for Completion: The Town's Clerk-Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

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.

See the Corrective action plant for chart/table

Auditor’s Recommendation: It is recommended that the Organization: Implement and enforce the updated procurement policy. Train staff on Federal procurement requirements. Implement a checklist or control mechanism to ensure all required documentation is retained for each procurement transaction. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and agrees with the recommendation. The Organization updated its procurement policy in February 2026 to align with applicable Federal procurement requirements. Management will implement and enforce the procurement methods established in the updated policy, provide training to relevant staff on Federal procurement requirements, and maintain the required supporting documentation for applicable procurement transactions going forward.