Corrective Action Plans

2023-002 Compliance and Internal Controls over Procurement (Material Weakness and Noncompliance) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to procurement are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Corrective Action: In alignment with the recent leadership transition, a comprehensive policy and procedure manual has been established to ensure our procurement practices meet HUD guidelines. The following outlines our updated procurement policy: 1. Compliance with Standards: All procurement of property (goods, supplies, or equipment) and services must adhere to the standards of conduct and conflict-of-interest requirements outlined in 2 CFR 200.317 and 200.318. 2. Micro Purchases (Under $9,999): Temenos CDC (TCDC) will document the reasonableness of costs for all micro purchases to ensure appropriate spending practices. 3. Small Purchases ($10,000 and above): For small purchases exceeding $10,000, TCDC will solicit a minimum of three bids for services to promote competitive pricing. 4. Vendor Vetting: 1. All new vendors will be vetted through the SAM (System for Award Management) Department prior to the initiation of services. 2. Continuous service providers will be subject to an annual vetting process to ensure ongoing compliance and quality. These measures are designed to reinforce our commitment to transparency, accountability, and compliance with HUD requirements. Responsible Parties: Sandra Robicheaux - Executive Director Madelyn Wages – Director of Supportive Services Ramona Edwards – Property Manager Date to be Corrected: Implementation for above changes went into effect 6/01/2024

Response to finding 2023-002 – Procurement, Suspension, and Debarment Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-002. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization operated with significantly reduced staffing and limited capacity, which delayed the development of procurement policies addressing suspension and debarment requirements. Initial governance updates occurred during the 2025 Q4 Board meeting, where the Board approved a revised version of the By-Laws focused on correcting deficiencies in board structure and conflict-of-interest provisions. Procurement procedures recommended in this finding were not included in that initial revision but are scheduled for development and implementation as part of the 2026 rebuilding phase. Corrective Action taken in 2025: While no procurement-specific corrective action has yet been implemented, foundational updates to the By-Laws were approved at the 2025 Q4 Board meeting to address structural governance issues. These updates establish the basis for incorporating required procurement, suspension, and debarment procedures. The Operations Manager and Advisory Consultant have begun drafting updated procurement policies to ensure compliance with federal requirements. Corrective Action Planned for 2026: Draft procurement, suspension, and debarment policies will be completed and presented to the Board as a formal resolution in early 2026. Upon approval, these policies will be incorporated into the By-Laws and will take immediate effect. The Board has also approved the planned hiring of a consultant with Executive Director and strategy experience in 2026 to support policy implementation, training, staff alignment, and ongoing compliance review. These measures will ensure full compliance with procurement requirements throughout the 2026 operating year and beyond.

Finding 2023-003: Test no 15 is for Department of Education and the rest are for Department of Health. • For test no. 15, obligation 361854 – Of 3 quotations obtained for a small purchase transaction, the highest quotation was selected, there was no documented justification to support the procurement selection. • For test no. 16, obligation 372216 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 17, obligation 372215 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 22, obligation 334914 – The procurement file included 2 quotations and a justification form that did not relate to the transaction as it cites an explanation for purchasing goods from other vendors unrelated to the actual transaction. Of the 2 vendors included, there did not appear to be a notable difference in goods/services offered, however the higher of the 2 was selected. Consequently, we could not determine the ultimate basis for vendor selection. • For test no. 30, obligation 358537 – The procurement as sourced from one vendor and lacks additional quotations. There was no documented justification for the sole-source procurement. Root Cause Analysis Ineffective documentation filing and retention controls, further impacted by the relocation of the State Treasury office. Corrective Actions • Strengthen procurement documentation controls and ensure rationales and justifications for vendor selection are retained in procurement files. Responsible Parties Director of Education and its administrative officers Director of Health and administrative officers Director of DOTA, certification and payable section Timeline Verification of Effectiveness Periodically verify the department's purchases to ensure that no instances of noncompliance are still taking place.

Finding 2023-003: Test no 15 is for Department of Education and the rest are for Department of Health. • For test no. 15, obligation 361854 – Of 3 quotations obtained for a small purchase transaction, the highest quotation was selected, there was no documented justification to support the procurement selection. • For test no. 16, obligation 372216 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 17, obligation 372215 – The procurement was sourced from one vendor and lacks additional quotations. There was no documented justification to support the sole-source procurement. • For test no. 22, obligation 334914 – The procurement file included 2 quotations and a justification form that did not relate to the transaction as it cites an explanation for purchasing goods from other vendors unrelated to the actual transaction. Of the 2 vendors included, there did not appear to be a notable difference in goods/services offered, however the higher of the 2 was selected. Consequently, we could not determine the ultimate basis for vendor selection. • For test no. 30, obligation 358537 – The procurement as sourced from one vendor and lacks additional quotations. There was no documented justification for the sole-source procurement. Root Cause Analysis Ineffective documentation filing and retention controls, further impacted by the relocation of the State Treasury office. Corrective Actions • Strengthen procurement documentation controls and ensure rationales and justifications for vendor selection are retained in procurement files. Responsible Parties Director of Education and its administrative officers Director of Health and administrative officers Director of DOTA, certification and payable section Timeline Verification of Effectiveness Periodically verify the department's purchases to ensure that no instances of noncompliance are still taking place.

2023-008 – Documentation of the procurement process was unavailable for certain vendors Auditor Recommendation: Management should revise its documentation system to allow for centralized and accessible storage of support for its vendor procurement process. Action Taken: Management will implement a process to formally document vendor selections. Name of responsible person: Tonja Boykin, COO Anticipated completion date: December 2025.

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

Corrective Action Plan: Beginning with the 2026-2027 school year, the organization will follow our Federal Funds Procurement Policy and obtain a minimum of 3 bids for vendors whose purchases exceed $100,000 a year. Anticipated Corrective Action Plan Completion Date: June 30, 2027.

Suspension and Debarment Recommendation: The auditor recommends the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page which includes the date verified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Consulting with TACHC to develop policies to be approved by the organization’s Board of Directors and implement procedures to properly complete vendor’s sam.gov verification. Name(s) of the contact person(s) responsible for corrective action: David Rodrigues. Planned completion date for corrective action plan: December 2025.

Procurement Recommendation: The auditor recommends the Organization revise its procurement and suspension and debarment policies to be consistent with the Uniform Guidance and consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Consulting with TACHC to develop policies to be approved by the organization’s Board of Directors, and implement procedures to meet the suspension and debarment requirement Name(s) of the contact person(s) responsible for corrective action: David Rodrigues. Planned completion date for corrective action plan: December 2025.

Finding Reference Number: 2023-002 Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the serious nature of this finding and the compliance required with 2 CFR sections 200.318 through 200.327, as well as Part 1326 for vendor exclusions. The Controller and Director of Finance updated procedures to document requirements for all procurement activities, regardless of type. We also understand these findings are repetitive from the 2021 and 2022 audits; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2023 audit, as 2021 and 2022 audit reports were not received until 2024. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. Resolution of this issue began in 2024 as the procurement policy was distributed to staff and reviewed during staff meetings. Further, the policy and procedures for procurement were reviewed directly with programmatic staff to ensure that they were familiar with the policies and what is required to be captured for documentation to ensure all procurement activities adhere to the company policies. Continuing education for staff will be provided in subsequent years to ensure continued compliance with these policies. Periodic reviews of the procurement activities will be performed to ensure compliance with these procedures to mitigate the risk of continued deficiencies. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: December 2024

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31, 2025

Finding 2023-002: Procurement standards must be followed Plan: The Executive Director received guidance from an additional attorney familiar with school RSAs and now understands that sub-contractors under the direct contractor must also follow the three bid rule. This has been vetted and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all future purchases comply with 2 CFR. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: This was corrected approximately October 2023. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

Condition: Controls in place were not adequate to ensure the policy included appropriate procurement thresholds and methods. Planned Corrective Action: Management understands the importance of adhering to procurement thresholds and methods. Procurement policies and grant policies will be updated to include federal thresholds and methods to reflect federal Uniform Guidance. Contact person responsible for corrective action: Stephanie Cihon and Andy Vollmar Anticipated Completion Date: October 31,2025

The Auditor’s Office will work with the Commissioner’s Office and Prosecutor’s Office to implement the required policies.

SHLNFB will draft a “Federal Grants Management Policy Manual” and implements related procedures which will be in compliance with Uniform Guidance (2 CFR 200.320) for micro-purchases. As of April 2025, there is a Procurement Policy in place and contracted vendors and staff are required to follow the policy. For food purchases that are in relation to federal funding, due to multiple smaller purchases, the requester must obtain 3 quotes and complete a spreadsheet indicating why the vendor was selected. It is then approved by the Director of Operations to move forward with the purchase.

U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Passed Through Minnesota Department of Human Services Pass Through Number: H55230010 Award Period: 2023 Recommendation: We recommend the County follow their federal purchasing policy in all of their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are program specific 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 SNAP program managers to understand and adhere to federal purchasing policies. Name of the contact person responsible for corrective action: Tiffinie Miller, Deputy Director of Employment & Economic Assistance Planned completion date for corrective action plan: December 31, 2024

2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. During the audit period, the College operated under procurement policies and procedures inherited from New Mexico State University (NMSU), as the College had recently separated from NMSU. The procedures were followed in good faith. Two College employees successfully completed Certified Procurement Officer (CPO) training in July 2021 and were recertified in March 2024. Another employee became certified in February 2024, and the College is having two additional employees participate in fiscal year 2025. This training demonstrates the College’s commitment to compliance and proper procurement practices. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy Update o The institution will revise its procurement policies to fully align with Uniform Guidance (2 CFR §200.320) requirements for small purchases. Policies will specify:  The dollar thresholds for small purchases  Requirements for obtaining at least two or more quotes, as applicable.  Acceptable methods of documenting quotes (written, online or verbal with notation).  Exceptions or special circumstances, if applicable under federal regulations. • Procedure Implementation o Detailed procedures and checklists will be developed to ensure consistent documentation of all small purchases under federal awards, including price comparisons and vendor justification. • Training o Procurement and grant personnel will receive training on the revised small purchase procedures to ensure understanding of documentation and compliance requirements. • Monitoring: o A periodic review process will be established to verify adherence to small purchase procurement requirements, with corrective actions taken if any deficiencies are identified. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager

2023-002 Internal Controls over Period of Performance and Procurement, Suspension and Debarment (Material Weakness) Recommendation: Director of Housing and Supportive Services and any other approvers should be retrained to identify allowable and reasonable costs under the grant before approving such requests. Corrective Action: All leadership and designated line staff were retrained on reviewing and approving supporting documentation for expenditures in accordance with the federal guidelines. Responsible Parties: Ritchie T. Martin, Jr., Chief Human Services Officer Date Corrected: Immediately

In regard to the village not having a written policy in place for the requirements outlined in the Code of Federal Regulations regarding the villages received Coronavirus funding, as previously stated the village does not routinely receive federal funds and was not aware at the time of having such a policy. The village is currently working with the village solicitor to rectify this issue. A new policy will be implemented to resolve this issue. – Mayor M. Shane Patrone

The County will adopt a procurement policy in compliance with the requirements of the Uniform Guidance. This will be done with an ordinance passed by the county board.

Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: KSU will review its procurement policies to ensure that the policies are in compliance with uniform guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Fran Pinkston, Director of Purchasing & Procurement Planned completion date for corrective action plan: December 31, 2025

Fiscal Year 2023 Single Audit Corrective Action Plan Finding Number: 2023-004 Procurement Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into contracts for services under the grant. Also, the CMHSP did not verify that the vendors were not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Planned Corrective Action: The finance team will make sure proper bids and documentation are kept as proof of sole source provider and why certain vendors were chosen over others. The finance team will ensure that any procurement for vendors are shared with the contract management team to verify that the vendors were not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract. Contact Person: Kevin Hartley, CFO 231.633.2171 Kevin.hartley@nlcmh.org Anticipated Completion Date: 10-1-24

Views of Responsible Officials and Planned Corrective Actions: Agree with recommendation. A draft procurement policy has been prepared. It will be modified to ensure compliance with procurement of property or services required under a Federal award. Employees with procurement responsibilities will be required to follow the policy.

Response to the Schedule of Findings and Questioned Costs by Schriver Carmona, CPA on Audited Financial Statements of Beasley Brown Community Development Corporation for the Year Ended December 31, 2023 Finding #2023-001: BBCDC was unaware of the compliance requirement, and did not follow its written procurement policy, which resulted in $324,000 of questionable costs that caused it to not meet the procurement requirements for Congressionally Funded Community Projects. Action: At its Board of Directors meeting March 17, 2025, the Beasley Brown Community Development Corporation took the following action: It voted to revise its procurement policy to include a section entitled "Procurement Policy Procedures applicable to Non-Federal Entities.” This section will include all requirements stated in CFR 200.318 – 200.326. Procedures will require documented evidence of all proposed purchases and contracts under this section per CFR 200.318 – CFR 326 and approval by the Board of Directors or designated persons. The Board also moved that periodic training on CFR 200.318 – CFR 200.326 must be provided to the Board of Directors and other designated persons. Rev. Dr. Melvin Wilson, Jr., Chair – Board of Directors, will be responsible for ensuring the corrective action plan is implemented. The corrective action was implemented beginning March 18, 2025.

Schedule of Corrective Action Plan For the Year Ended December 31, 2023 Finding: 2023-01 Significant Deficiency and compliance over Procurement and Suspension and Debarment. Responsible Official’s Response and Corrective Action Plan Rising for Justice, Inc. (RFJ) implemented a corrective action plan effective October 1, 2023. RFJ updated its Office Operations Manual to include a process for verifying that vendors are not debarred from doing business using federal funding, by reviewing the federal System for Award Management (SAM) at www.sam.gov. Documentation of vendor verification and procurement compliance is maintained in the vendor files and reviewed with final approval by the Executive Director. Procurement Policy Summary (Effective October 1, 2023) RFJ adopted a comprehensive Procurement Policy to ensure that all purchases and contracts are executed through an open, fair, documented, and competitive process. Key provisions include: •Applicability: The policy covers all purchases and contracts regardless of funding source or total cost,unless specifically exempted. •Allowability: Expenditures must be necessary, reasonable, allocable, and documented. •Conflict of Interest: All staff must comply with RFJ’s Conflict of Interest Policy; no personal gain fromvendor relationships is permitted. •Authorization: The Executive Director approves contracts per policy thresholds. Delegation ofauthority must be in writing. •Competition Requirements: oUnder $10,000: No formal bidding required; professional judgment applies. o$10,001–$25,000: At least two quotes required. oOver $25,000: At least three quotes and/or RFPs. •Sole Source & Emergency Purchases: Allowed with proper documentation. •Federal Debarment Check: Vendors for federal contracts over $25,000 must be verified throughwww.sam.gov. Conclusion: All the vendors listed in the auditor’s findings for FY23 were selected before the corrective action was taken in October 2023. Person Responsible for Corrective Action Plan Chijioke Akamigbo, Executive Director April 15, 2025