Corrective Action Plans

FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that price reasonableness analyses are performed and documented prior to entering into agreements with vendors in accordance with Uniform Guidance procurement requirements. The University will implement the following corrective actions: • Continue to monitor and review procurement policies and procedures for changes in applicable federal requirements and institutional practices. Procurement policies, procedures, and related documentation tools will be updated as necessary, and the standardized procurement checklist will be periodically reviewed and revised to ensure alignment with current procurement policies and Uniform Guidance standards. • Require supervisory review of procurement transactions to ensure all required procurement documentation, including price reasonableness determinations, is completed and retained prior to final approval of vendor agreements. • Provide training to procurement and departmental personnel involved in federally funded procurements regarding Uniform Guidance requirements and documentation standards. • Conduct periodic monitoring of procurement files to verify ongoing compliance with procurement policies, procedures, checklist requirements, and applicable federal regulations. These corrective actions will strengthen the University's internal controls over procurement activities and help ensure compliance with Uniform Guidance requirements related to procurement documentation and vendor selection. Individual(s) Responsible for Corrective Action Plan: Randi Vandegrift, Strategic Sourcing Manager John Skjeveland, Controller Estimated Completion Date: September 30, 2026

Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that updates procurement thresholds and outlined the standard for non-competitive procurement, requiring that sole-source determinations meet one of the specific allowable criteria under 2 CFR §200.320(c). 2. Rebuilding Together will further update the Procurement Policy to require that for noncompetitive procurements, management will prepare and retain contemporaneous written justification in the form of a sole-source justification memo demonstrating that the procurement meets one of the allowable criteria under 2 CFR §200.320(c), supported by appropriate documentation such as market research or evidence of exclusivity. The sole-source justification memo will be reviewed and approved by a manager senior to the staff member leading the procurement before the determination is finalized. 3. Rebuilding Together has developed standardized Micro-Purchase and Small-Purchase Procurement Memo templates that require documentation, at the time of procurement, of vendor selection rationale, price/cost reasonableness, competitive quotes obtained (as applicable), conflict-of-interest certification, and debarment/suspension verification. 4. Rebuilding Together is finalizing a Speaker Procurement SOP, which provides speaker-specific procurement guidance in accordance with 2 CFR 200. 5. Relevant staff (Development, Development Operations, Network Advancement, Communications, Grant Operations, and Finance) will receive training on the revised Procurement Policy and Speaker Procurement SOP. Anticipated Completion Date: The revised Procurement Policy became effective January 1, 2026. Additional edits to the Policy will be made implemented by September 15, 2026. Finalization of the Speaker Procurement SOP and related staff training are anticipated to be completed by December 31, 2026. Responsible Contact Person: Emma Weltzer, Director, Development Operations & Federal Grants

The Company will enhance the existing procurement policy for grant-funded purchases to align with federal procurement guidelines. Price quotations and comparisons will be obtained from an adequate number of vendors and such quotations and comparisons will be retained to support vendor selection. Anticipated Completion Date: 12/31/2026 Responsible Contact Person: Rebecca Horn, Controller

Corrective Action Plan Finding No.: 2025 - 002 Condition: The District procured $885,950 of services from a food service vendor and did not follow the formal methods of procurement outlined in 2 CFR 200.320(b)(2), 105 ILCS 5/10-20.21, and their established procurement policy as they did not procure the services through a competitive request for proposal process. Plan: While the district did obtain a two-year waiver from the Illinois State Board of Education regarding Food Service procurement regulations, management concurs with the finding. The District will strengthen its procurement procedures to ensure purchases subject to the Uniform Guidance procurement requirements are conducted using the appropriate procurement method and adequately documented. Management will provide additional training to personnel responsible for federal procurements and implement a review process to verify compliance with federal procurement requirements prior to contract award. These procedures will be implemented for all applicable procurements beginning in fiscal year 2027. Anticipated Date of Completion: August 30, 2026 Name of Contact Person: Mr. Harrison Neal, Assistant Superintendent of Business and Finance

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 252MN101S2514 – 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55250010 and H58260061 Compliance Requirement: Procurement Award Period: 2025 Recommendation: We recommend the County follow their federal purchasing policy in all their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are specific to each program to ensure this properly occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will continue to work with program managers to understand and adhere to federal purchasing policies. Name of the contact person responsible for corrective action: Dana DeMaster, Director of Employment & Economic Assistance Planned completion date for corrective action plan: December 31, 2026

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 Number and Title: Federal Award Number: Questioned Costs: Description: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.027A- Grants to States; 84.173A- Preschool Grants H027 A230073 (Year: 2024), H027 A240073 (Year: 2025), H173A240081 (Year: 2025) $4,500 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 has evaluated and improved internal control procedures by processing expenditures through the approved financial management system to ensure that required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Anthony Parrillo, Chief Financial Officer Telephone: 912-739-3544 Email: aparrillo@evanscountyschools.org

Condition: For two projects procured during the year ended December 31, 2025, the Township did not obtain competitive bids or quotes for the project as required by 2 CFR 200.320. Planned Corrective Action: The Township will implement processes and procedures to ensure that vendors used on projects funded with federal grants follow the procurement rules as required by the federal standards. Contact person responsible for corrective action: Barbara Miller, Accounting Mgr. Anticipated Completion Date: 9/30/2026

Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that contractors were not suspended, debarred, or excluded was not maintained in the files. Management will conduct a review of contracts to ensure required documentation is obtained and properly filed and will update internal policies to include a checklist to ensure compliance prior to contract execution. • Documentation Review: We will conduct a thorough review of our contracts and ensure that all necessary debarment, suspension, or exclusion from receiving or participation in federal awards are obtained and properly filed. • Policy Improvement: We will update our internal policies to include a checklist for all new contracts, which will ensure that documentation related to debarment, suspension, or exclusion is acquired before proceeding. For Items #2, #4, and #5, management concurs with the finding related to Independent Cost Estimate documentation. Management acknowledges that documentation supporting cost estimates was not maintained prior to solicitation. Management will implement a standardized process for documenting Independent Cost Estimates and will conduct periodic reviews to ensure compliance. We acknowledge the lack of documentation on the Independent Cost Estimate (ICE) procedures prior to solicitation. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. Moving forward, we will implement measures to ensure that appropriate documentation is created and maintained for all cost estimates. This includes developing a standardized process for documenting ICE procedures and conducting regular reviews to ensure compliance. For Item #15, management does not concur with the finding. Management states that documentation supporting the Independent Cost Estimate was included in Purchase Order No. PO251039. Management refers to the Small Procurement Abstract/Price Analysis Form, which documents prior pricing information used to support cost reasonableness. Small Procurement Abstract/Price Analysis Form that shows ICE information detailing the last price paid for Consumable Inventory. AMP 2 Response: We acknowledge the need to strengthen monitoring controls to ensure full compliance with applicable procurement, suspension, and debarment requirements. We recognize that verification of contractor eligibility and proper documentation of procurement actions are essential components of an effective internal control system. We acknowledge that documentation of the required suspension and debarment verification was not included in the procurement file at the time of purchase. Although this verification was completed after the fact, we have now confirmed through SAM.gov that the vendors involved were not suspended, debarred, or otherwise excluded from receiving federal funds. To prevent this issue going forward, we have implemented a strengthened control requiring staff to perform and document SAM.gov verification prior to every procurement action, including micro purchases. Verification results will be printed or saved as PDF and filed with each procurement record to ensure full compliance with 2 CFR 200.214 and HUD procurement requirements. These corrective measures will ensure that all future procurements include timely and complete documentation of suspension and debarment checks. Corrective Actions Implemented 1. Suspension & Debarment Verification Controls Strengthened Effective immediately, we have implemented enhanced procedures requiring Housing Administrative Officer personnel to verify all prospective contractors and vendors against the SAM.gov Exclusions Database prior to award. 2. Enforcement of Minimum Solicitation Requirements AMP 2 has reinforced compliance with 5 GCA Chapter 5 and internal procurement SOPs requiring minimum solicitation thresholds: • Three written quotes for small purchases above the micro purchase threshold. • Written justification for any noncompetitive procurement, including emergency, sole source, or inadequate competition. • Staff have been retrained on documentation standards, including price reasonableness, vendor selection rationale, and procurement history requirements. 3. Strengthened Management Oversight and File Review To prevent recurrence, AMP 2 will review all required documentation—including SAM verification, solicitation records, and justifications—is complete. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. These corrective actions strengthen internal controls, ensure proper oversight, and prevent recurrence of the deficiencies identified. AMP 3 Response: For Items #6 (PO251249) and #10 (PO250104), management does not concur with the finding. Management explains that the purchase orders were structured similarly to indefinite delivery/indefinite quantity arrangements to support recurring and variable requirements throughout the fiscal year. Management states that Housing Administrative Officers solicited pricing from multiple qualified vendors at the beginning of the fiscal year to establish competitively awarded pricing schedules. By securing pricing in advance, management was able to address anticipated needs efficiently without preparing separate Independent Cost Estimates for each task, while maintaining fair and reasonable pricing through competition. For Item #22 (BPA250203), management concurs with the finding. Management noted that the blanket purchase agreement was established to support anticipated advertisement services related to the opening and closing of the AMP3 waitlist. At the time, management determined that only one vendor provided hard-copy print publication services locally and was uncertain whether electronic-only media outlets met program needs. Based on this determination, the agreement was executed. However, management acknowledges that the procurement file should have included documentation of market research performed. Management will ensure that future procurement files include adequate documentation of solicitations, market research, and any sole-source or limited-source justifications, as applicable. AMP 4 Response: AMP4 consistently adheres to all procurement policies and requirements prior to executing contracts, agreements, or purchases. Staff will continually ensure documentation is complete and concise with all procurement procedures. AMP4 Response to items: Item #8. We disagree with this finding. Documentation was completed to continue procurement services. See attached documentation labeled as “#8”. Item #s 17, 19, and 20. We disagree with this finding. Documentation on file to support procurement transactions being conducted in a manner that provided for full and open competition. See attached documentation labeled as “#17, #19, #20”. Item # 23. We disagree with this finding. Documentation on file to show evidence services were awarded equally among multiple vendors. See attached documentation labeled as “#23”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

Management agrees with the finding and acknowledges that procurement approval documentation was not consistently retained during the audit period. Management notes that the finding primarily relates to documentation and retention of approval evidence, including reliance on verbal approvals and documentation gaps associated with system transitions. To address this finding, management has implemented corrective actions requiring documented, written approval for procurements prior to execution. The organization will use standardized approval workflows to ensure procurement approvals are properly evidenced, retained, and available for audit review. Management has also established a centralized repository for procurement records to improve accessibility, consistency, and document retention. In addition, management will enhance data backup and migration procedures to reduce the risk of documentation loss during future system transitions. These procedures will be incorporated into formal policies and standard operating procedures. Management will monitor compliance to ensure procurement documentation and approval controls are consistently followed across federally funded programs. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026. Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

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 Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) $6,267 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: To address this deficiency and prevent recurrence, the District will implement the following corrective actions: 1. Immediate Reinforcement of Quote Requirements Effective immediately, all School Nutrition and applicable district staff will be required to obtain and document price or rate quotations from a minimum of two qualified sources for all. 2. Pre-Approval and Verification Controls A pre-payment review process will be enforced requiring verification that: o Required quotes are documented o Procurement method aligns with federal thresholds o Vendor selection is properly justified o Payments will not be approved without complete documentation. 3. Staff Training and Accountability Mandatory training will be conducted for all School Nutrition Managers and staff involved in procurement to reinforce: o Federal procurement requirements o Documentation expectations o Internal control procedures Estimated Completion Date: July 31, 2026 Contact Person: Matoshia Grant, School Nutrition Director Telephone: 478-986-1390 Email: Matoshia.grant@jones.k12.ga.us Signature:Tonya Merritt Title: Cheir Financial Officer

Procurement – Assistance Listing No. 93.224/93.527 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: • Review Contract and procurement policies and procedures. • Compare current procurement process and training to the policies and identify areas for correction and improvement. • Update Policies and procedures as needed. • Implement procedures to review vendors on a periodic basis. • Implement procedures and assign responsibility for checking off that procurement documentation exists and is in the vendor folder or designated area. • Retrain staff involved in procurement on updated procedures. • Monitor process and adjust as needed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: January 2027

Management Response AIHEC concurs with this finding. AIHEC's procurement approval workflow is processed through its Concur system; however, it was not previously communicated to procurement and program staff that sole-source procurements also require a separately signed sole-source justification, in addition to routing approval through Concur. As a result, certain sole-source transactions were approved through the Concur workflow without the required signed justification on file. AIHEC is modifying its sole-source justification form to include the appropriate required signatures and is updating its procurement procedures to clarify that, for any procurement identified as sole-source, the signed sole-source justification form must be completed and retained in the procurement file in addition to Concur approval. AIHEC will also conduct a quarterly internal self-review of a sample of procurement files, including all sole-source transactions, to confirm compliance with this updated policy, and will retrain procurement and finance staff on documentation requirements, including suspension and debarment verification. Estimated Completion Date September 30, 2026 Responsible Party Diane Robertsy, Director of Finance

HCS currently has in place Policy 2095 – Procurement Standards, which requires obtaining three quotes for goods and services above $5,000. This policy was not followed by the agency’s leadership when the goods and services referenced in this finding were procured, despite counsel recommending that it be followed. Corrective action taken during the prior year included termination of the individual who violated the policy. Beginning on 11/15/2024, the above-referenced policy has been, and will continue to be, adhered to. Because certain expenses related to the prior-year procurement activity trailed into the 2024–2025 fiscal year, the finding was repeated; however, no new violations of Policy 2095 occurred in 2024–2025. HCS will continue to monitor procurement activity and maintain full compliance with Policy 2095 going forward.

Corrective Action Plan Year Ended December 31, 2025 Finding 2025-001 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Corrective Action Plan: To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed introduced a Purchasing Compliance Program in November 2025. This program included training and oversight procedures for procurement. The training included ongoing quarterly purchasing training for end users and purchasing staff and new hire training. The purchasing team maintains training documents and ensures new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures are performed by the Assistant Director of Supply Chain Management and include auditing of purchase orders over the micro-purchase threshold to ensure proper documentation is present. We believe these steps address the procurement findings that have been identified; however, additional controls have been implemented to further ensure compliance. In January 2026, an additional approval step was added to the purchase requisition approval workflow in the procurement system for all federal procurements above the micro-purchase threshold. This step documents review and approval by the Assistant Director of Supply Chain Management or the Director of Finance after reviewing the procurement to ensure compliance with procurement requirements and policies. In addition, Texas Biomed is developing a new sole source justification form for the end users to use. This will include more detail to better document sole source justification, and the end-users will be advised of the new format and how to use it. The Assistant Director of Supply Chain Management also leads efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training November 2025 • Oversight procedures developed November 2025 • Quarterly training sessions January, April, July and October 2026 • New user training April 2026 • New sole-source template developed and deployed July 2026 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: Corrective action to address internal controls and noncompliance was implemented as of November 2025. Management continues to implement best practices in procurement, including the procedures mentioned above.

Corrective Action Plan Year Ended September 30, 2025 Finding 2024-001 AL Numbers: Various assistance listing numbers Program: Research and Development Cluster Correction Action: Brown Health management concurs with this finding. Based on the review, the underlying procurement procedures were generally performed in accordance with established policy; however, supporting documentation was not consistently retained to evidence compliance. We have already initiated re-training at the department level and will be performing a detailed review of current purchase history to ensure appropriate documentation is retained. For fiscal year 2026, we will be reviewing all federal grant activity to ensure the appropriate documentation is maintained and/or sole source documentation is prepared including a lookback analysis of expenditures to date that did not retain the proper documentation. Additionally, we will review automated control enhancements within our ERP system where possible to assist in recognizing compliance rules in advance of spend. Contacts: Stephen Almonte, Vice President and Corporate Controller Salmonte3@brownhealth.org Bharat Ramratnam, MD, Senior Vice President of Research BRamratnam@brownhealth.org Planned Completion Date: October 31, 2026

The Institute's procurement policy will be updated to the passage of Act 202 1-296, now codified at Code ofAlabama 1975, Section 41-4-110, et seq.

The District will gather two qualified vendors for purchases of $10,000 to $25,000. The District will have Board approval for purchases exceeding $25,700. In addition, the Food Service Director will exercise care to order items on the bid list, but will not be limited to only items on the bid list as new items become available.

Finding 2025-002 – Significant Deficiency Award No.: 21.027 Federal Grantor: U.S. Department of Treasury, Passed-through the County of Butte, Pass-through Grantor’s Number X25534. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The Agency’s procurement policy does not adequately document procurement requirements under the Uniform Guidance or contract provisions under Appendix II to Part 200 of the Uniform Guidance. Criteria: Uniform Guidance, Section 200.318(a) indicates “the recipient or subrecipient must maintain and use documenting procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327”. Required contracting provisions are documented in Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Cause: The Agency’s procurement policy needs to be updated to document the requirements of the Uniform Guidance. Effect: The Agency’s procurement policy does not comply with the requirements of the Uniform Guidance, which could result in procurements that do not comply with the Uniform Guidance and the awarding agency disallowing the federal award and requesting the return of the award. Context: The Agency’s procurement policy complies with many requirements of the Uniform Guidance, but the policy does not comply with certain required provisions, including the thresholds for micro purchases, simplified acquisition threshold and full public procurements and the requirements for sole sourcing procurements under section 200.320. The procurements tested were found to comply with procurement requirements under Uniform Guidance even though the policy did not include all of the required provisions. Recommendation: The Agency should update its procurement policy to reference Uniform Guidance §§ 200.317 through 200.327 and should reference contracting provisions under Appendix II to Part 200 to be in compliance with Uniform Guidance prior to procurements being made under future federal awards. Views of Responsible Officials and Planned Corrective Actions: The procurement policy will be updated to include procurement guidance under Uniform Guidance §§ 200.317 through 200.327 and contracting provisions under Appendix II to Part 200 – Contract Provisions for Non-federal Entity Contracts Under Federal Awards. Title of Responsible Party: Finance Manager Implementation Date: By September 22, 2026

Prairie-Hills Elementary School District 144 07-016-1440-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025 - 003 Condition: The District procured $285,867 from a food service vendor (Gordon) and $539,977 from another food service vendor (Sysco Business Services) and did not follow the formal methods of procurement outlined in 2 CFR 200.320(b)(2) as they did not procure the services through a competitive request for proposal process. Plan: The district will become a member of HPS, which is a (Group Purchasing Organization) that manages competitive bidding by aggregating the collective buying power of thousands of member organizations to negotiate lower prices and better terms with vendors. Instead of an individual school district running its own expensive and legally complex Request for Proposal (RFP) process, HPS acts as the central procurement agent. They handle the administrative burden of advertising, evaluating, and legally vetting bids on behalf of their members. Anticipated Date of Completion: July 1, 2026 Name of Contact Person: Dr. Alicia Evans – Consultant - Business Manager

FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 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: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us

Adeline Montessori School will comply with its procurement policy related to noncompetitive procurement transactions for future purchases.

Procurement, Suspension, and Debarment Auditor Description of Criteria, Condition, and Effect: Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision In addition, the Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to Procurement (including bidding and a conflict of interest policy) (§200.318). For one of the two vendors tested, the YMCA was unable to provide documentation to support that competitive bidding was performed in accordance with the YMCA's policies and procedures. Although the YMCA has processes in place to cover these areas, we noted during review of procurement policies, that management has two procurement policies, one for general competitive bids and one for federal funds. We noted that while the federal funds procurements thresholds are in line to what is required by 2 CFR 200.318, the policy was not being followed consistently. As a result of this condition, one vendor was paid with federal funding for which appropriate procurement records were not maintained in accordance with federal procurement standards. The YMCA did not fully comply with the Uniform Guidance applicable to the above noted grant. Auditor Recommendation: We recommend that the YMCA review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. Corrective Action: Although we performed the proper procedures, the passage of time resulted in a misplacing of the supporting documentation. We relied upon legal counsel to retain the documentation. This was a unique and one-time award. In the future, we will take responsibility for the retention of the supporting documentation, Responsible Person: Phil Platz, CFO Anticipated Completion Date: 6/12/2026