Corrective Action Plans

2025-003 Procurement Corrective action planned: CSV will enforce its procedure policy that all competitive procurement transactions above the micro-purchase threshold, when expenditures are charged to a federal award, must have complete supporting documentation retained for at least four years after final payment, in accordance with 2 CFR 200.320. This will be accomplished by providing training for procurement, finance, and administrative staff on: • Recognizing when a transaction exceeds the threshold. • Collecting and organizing supporting documentation. • Understanding retention periods and storage requirements. The Procurement Manager shall oversee compliance with the threshold and retention requirements. CSV shall conduct periodic audits to: • Review procurement files for completeness and compliance with retention requirements. • Identify gaps or missing documentation and correct them promptly. • Document audit findings and corrective actions. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

FINDINGS—FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Environmental Protection Agency 2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the Village evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The Village is reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Ryan VanDeWalle, Village Administrator and Melanie Wiskow, Finance Director/Treasurer Planned completion date for corrective action plan: The Village is evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Ryan VanDeWalle, Village Administrator at (715) 359-3660.

We followed 2 CFR 200.320(c)(2). Research expertise is unique and only available from subawardees selected for each specific project. It is a fundamental tenet of research. A competitive bidding process is not envisioned, nor practical when preparing grant submissions. All subawardees and contractors have a written justification and review, along with letters of support in the initial grant application.

Time and Effort - Corrective actions were implemented immediately upon identification of the control weakness and prior to the conclusion of the audit. Time-and-effort certifications were subsequently obtained for the affected employees. In addition, the district has enhanced its payroll adjustment procedures involving federal funds by incorporating an additional checklist item within the approval routing process to ensure required time-and-effort certifications are obtained and documented before payroll adjustments are finalized. Procurement Requirements - The following corrective actions will be taken: • Provide targeted staff training related to Federal procurement requirements, including noncompetitive procurement standards under 2 CFR 200.320. Provide additional training focused on internal controls, procurement documentation requirements, and drafting clear procurement justifications. • Update the district’s sole source/noncompetitive procurement documentation form to specifically incorporate and address the five allowable rationale methods identified under 2 CFR 200.320. • Implement additional internal review procedures to ensure procurement files contain sufficient written justification and support documentation prior to approval and execution.

Personnel Responsible for Corrective Action: Karla Clubine, Chief Executive Officer, David Cichocki, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Planned Corrective Action: Management accepts the recommendation. It will modify and strengthen our policy and procedure regarding the procurement process to reflect the alignment with federal regulations. The Hospital will begin performing and documenting suspension and debarment checks on all vendors/contracts funded with grants in fiscal year 2026.

Finding 2025-003: Procurement, Suspension and Debarment The single audit report included the following recommendation: EY recommends that Amtrak include legal expenses within their procurement, suspension and debarment policy as outlined within each of the grant agreements. Management Response/Status of Action Plans: Pursuant to Section 26(j) of Amtrak’s annual grants, Amtrak’s policy is to fund most law firm engagements with Program Income without applying grant requirements that apply to other procurements. In FY2025, this was the case for all law firm engagements charged to operating activities. Also, in FY2025, Amtrak had a portion of its legal expenditures charged to capital projects based on the nature of the legal work performed. These capital projects were funded with federal grants. For legal expenditures which are by their nature related to projects funded by grants, Amtrak acknowledges the need to have the proper procurement process including competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-down based on the grants. By the end of FY2026, the Law Department will review and update its internal procedures to better prevent recurrence of legal expenditures that did not have proper competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-downs from being charged to projects funded by grants. As part of that review, Amtrak will consider whether it may be appropriate to utilize the Company’s broader procurement policies. The contacts for this item are Lucia Butts, AVP Funding and Grants and Thomas Bloom, Deputy General Counsel and Corporate Secretary. Amtrak anticipates fully remediating this finding by September 2026.

Blood Diseases and Resources Research (ALN 93.839) Recommendation: We recommend that the Organization follows all procurement method requirements for purchases over the $10k micro-purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedure enhancements to its retainment and processing of documentation for simplified acquisition procedures. Including: quotes and other qualified sources documentation is attached to the relevant purchase requisition within our ERP system prior to submission of the requisition for review and approval; a three-step/tiered review and approval process. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: May 2026

This is the result of procurement transactions fonded with the ARPA Coronavirus State and Local Recovery Funds. The County did not conduct procurement transactions in a manner providing fair and open competition on two constrnction contracts. The comptrollers office will enhance procurement policies and review of federal grant funded purchases.

1. The District will no longer use federal funds for special education bussing. 2. The district will submit a separate request for approval for a noncompetitive proposal when procuring with an entity using federal funds to the Department of Education and Workforce.

Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.

Management will improve procurement compliance controls by: • The verification and retention of support that vendors are not suspended or debarred has been moved to be part of the accounts payable onboarding process of vendors and maintained in the vendor’s file in the accounting system. • Implementing a standardized checklist or form documenting that the verification that a vendor has not been suspended or debarred prior to contract execution and/or payment. • Providing refresher training to staff involved in procurement and accounts payable on documentation requirements.

The District is in the process of updating the Federal Procurement Procedures with the new thresholds that were issued in September. The District will get quotes for all items purchased with Federal funding in the future to avoid future findings. New Philadelphia City School District makes every effort to procure items based on the policies and procedures in place. We also follow the Uniform Guidance to the best of our ability.

The Town will revise procurement procedures to ensure that written contracts are executed prior to the commencement of work for material projects. Procedures will include emergency procurement protocols consistent with 2 CFR §200.320(c), requiring written justification and documentation when public exigency is used. Staff will be trained on federal procurement requirements, including contract execution and documentation standards.

Procurement – Assistance Listing No. 14.267 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: The Organization will update its procurement policy to include a formal pre‑approved vendor list and documentation requirements for all procurement methods. Management will standardize procurement files to ensure inclusion of required support, such as vendor selection rationale, cost or price analysis, and approval documentation. Procurement staff will receive training on updated policy requirements, and compliance will be periodically reviewed by management. Name(s) of the contact person(s) responsible for corrective action: Scott Russell Planned completion date for corrective action plan: 6/30/2026

Management concurs with the finding. Dir of Finance will take responsibility for ensuring adherence to follow all procurement policies and procedures. In addition, the VP of Finance will perform an Inservice to all key stakeholders within the facility under all procurement policies and procedures. The Dir of Finance is leading targeted training initiatives for finance staff and relevant personnel on the revised policy and procedures to ensure proper application. Quarterly we will review all purchases to ensure compliance with policies and procedures. These processes will be supervised by the VP of Finance/Director of Finance and were completed in February 2026.

The Town acknowledges that small purchase procedures were not followed in the transaction that occurred. Price reasonableness was not insured and bids were not obtained. The Mayor and Town Clerk shall improve procurement procedures and obtain a minimum of three bids on all projects that do not require public bidding or that are not on state contracts above the procedure threshold established by the Town. The Town will further update its written procurement policies and procedures to clearly define small purchase requirements, including quotation thresholds and documentation standards. Procurement staff will solicit and retain documentation of price or rate quotations from an adequate number of qualified sources for all small purchases. The staff will receive training under 2 CFR Part 200, including informal procurement methods and finally the Town will implement a supervisory review procurement file system to ensure compliance prior to payment, a checklist of sort to ensure proper document is secured.

Management's Response: The School District concurs with the recommendation. We recognize the importance of maintaining strong internal controls to ensure that all procurement activities are conducted in full compliance with Uniform Guidance (2 CFR Part 200) requirements. To address this recommendation, the District will enhance its existing procurement procedures by: 1. Developing and Formalizing Written Internal Controls. 2. Implementing Staff Training. 3. Strengthening Monitoring and Review Processes.

Audit Finding Reference: 2025-001 Planned Corrective Action: The Student Services and Food Service departments in Southwick-Tolland-Granville Regional School District will immediately ensure complete implementation of our internal control protocols regarding procurement. For any purchase that requires competitive procurement, we will conduct market research, obtain multiple quotes, or use the IFB/RFP process, if necessary. We will only engage in sole source procurement when we have determined that there is only one single provider of the good or service, and we will document that determination accordingly. We will enter into contracts with vendors when purchasing goods or services from them. We will use purchase orders to ensure that funds are encumbered and not over expended. Lastly, we will keep all procurement documentation on file, including quotes, bids, and sole source letters. Staff who engage in our purchasing process, including our Director of Student Services, our Director of School Nutrition, our Supervisor of Buildings and Grounds, and our Director of Technology will be retrained in our procurement protocols and will be expected to implement them immediately going forward. The Director of Finance and Operations will review all purchase requisitions to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 17, 2026 Person Responsible for Corrective Action: Nicholas Bernier Director of Finance and Operations Southwick-Tolland-Granville Regional School District

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

The Municipality will strengthen internal control and procedures to use adequate procurement process for the acquisition of goods and services in open competition to ensure that the Municipality receives a significant number of quotations from suppliers. Also, the Municipality will review and strengthen the purchasing procedures, to ensure that at least three quotations are requested from the suppliers. Implementation Date: Partially corrected Responsible Person: Mrs. María Ortiz Martínez Finance Department Director

Federal Agency: U.S. Department of Housing and Urban Development U.S. Department of Health and Human Services Federal Program Name: Continuum of Care Program Center for Substance Abuse Treatment - Certified Community Behavioral Health Clinic Assistance Listing Number: 14.267 93.696 Direct Federal Award Program: PA0029L3T002316 - Tioga Arms PA0568L3T002308 - Shelton Court 22TI85374A – Certified Community Behavioral Health Clinic Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Condition: As part of our audit procedures over the Organization’s procurement policy and the small purchase requirements under 2 CFR 200.320(a)(2), we sampled a total of five vendors who incurred costs exceeding $10,000 for each of the two major programs. For three of the five vendors selected, management was unable to provide written documentation demonstrating that price or rate quotations were obtained from an adequate number of qualified sources (generally 2-3 quotes) for purchases above the micro-purchase threshold ($10,000) and below the Simplified Acquisition Threshold ($250,000). This documentation should have included the names of suppliers contacted, prices quoted, and the justification for vendor selection. Recommendation: We recommend management update its policies and procedures over procurement to ensure compliance with 2 CFR Part 200. This includes requiring and retaining documentation supporting the use of small purchase procedures, obtaining price or rate quotations from an adequate number of qualified sources, and monitoring vendor expenditures on an aggregate basis to ensure the appropriate procurement method is applied. Management should also provide training for staff responsible for procurement activities to promote consistent compliance with federal requirements. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges the deficiency related to procurement documentation and compliance. While the Organization has procurement practices in place, documentation supporting the solicitation of price or rate quotations from an adequate number of qualified sources was not consistently maintained for certain purchases during the audit period. In certain instances, vendor selection was influenced by the need to ensure continuity of care and avoid disruption to critical services provided to clients. As a result, management prioritized maintaining established vendor relationships to support uninterrupted service delivery; however, formal documentation supporting this rationale was not consistently retained in accordance with procurement requirements. To address this matter, management will update and formalize procurement policies and procedures to ensure full compliance with federal requirements. This will include clearly defined documentation standards for all purchases exceeding the micro-purchase threshold, including retention of vendor quotes, identification of suppliers contacted, and justification for vendor selection—including instances where continuity of care is a determining factor. In addition, training will be provided to all staff involved in procurement activities to reinforce compliance expectations and documentation requirements. Management expects these corrective actions to be implemented in the current fiscal year and will conduct periodic reviews to ensure adherence and ongoing compliance. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026

Views of Responsible Officials: Management acknowledges the comment. Subsequent to fiscal year-end, we implemented enhanced internal procedures to ensure procurement activities are properly conducted and documented for consultants. In instances where a sole-source procurement is utilized, we now ensure that the justification and supporting rationale are thoroughly documented.

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

Procurement Noncompliance Auditor Description of Condition and Effect. During our testing of four procurement transactions charged to the federal award, we noted that the College procured goods/services totaling $18,750 from a single vendor using a sole source justification. The College did not obtain the required quotes for the purchase. Our review of the documentation determined that the rationale provided for sole source procurement did not meet the criteria outlined in Uniform Guidance. As a result, the College did not follow required competitive procurement procedures. Because competitive procurement procedures were not used, the College may not have obtained the best price or ensured full and open competition. Auditor Recommendation. We recommend that the College strengthen internal controls to ensure personnel verify and document that sole source criteria under 2 CFR §200.320 are fully met before awarding a procurement without competition. Corrective Action. Staff will retain documentation to substantiate single-source procurement transactions prior to award or contract execution and will be reviewed by the Controller. Responsible Person. Jennifer Dodson, Controller Anticipated Completion Date. June 30, 2026

Finding Numbers: 2025‐002, 2024‐002 Program Name/Assistance Listing Titles: Indian School Equalization; Administrative Cost Grants for Indian Schools, Special Education Cluster (IDEA) Assistance Listing Numbers: 15.042; 15.046, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School’s internal controls over procurement of goods and services were not adequate. - A change in office staff just before the audit visit made finding documentation related to procurement difficult. Efforts to improve in this area have been made and will continue to be a focus of the administration. Procurement procedures are in place and are being followed, but record keeping remains a challenge. A new hire in this area with training emphasis is needed.