Corrective Action Plans

Recommendation: The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Corrective Action Plan: The City of Scott will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.

Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance. Action Taken: Hubbs-SeaWorld Research Institute plans to modify its procurement procedures for federal grants to comply with 2CFR section 200.319 by continuing to require at least three bids (or a sole source statement, if applicable) for any purchases over the micro-purchase threshold, currently $10,000. In addition, we will monitor cumulative vendor purchases on a monthly basis to ensure that price or rate quotations are obtained from an adequate number of qualified sources, that is, at least three bids (or a sole source statement, if applicable.)

Auditor Description of Condition and Effect: Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Auditor Recommendation: We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. Corrective Action: The District identified the omitted prior year capital asset additions and has reconciled their UAAL expenditures and benefits accruals to agree with the required audit adjustments. The District will work to ensure the proper year end reconciliations are put into place to avoid future reporting errors. Responsible Person: Chad Baas, Business Manager. Anticipated Completion Date: June 30, 2025.

Management’s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance/ShelterCare 2. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 3. The anticipated completion date: a. New processes will be implemented by 11/1/2024.

2024-006 Procurement Corrective action planned: OMC’s Purchasing Policy will be updated to ensure compliance with federal regulations. Documentation will be reviewed by accounting staff. Anticipated completion date: 11-30-2024 Contact person responsible for corrective action: Cathy Liles, Director of Fiscal Operations

Corrective Action Plan Finding No.: 2024 - 001 Condition: The District procured $147,612 in goods from a food service vendor (Martin Bros. Distributing Company Inc.) and did not have documented support that price or rate quotations were obtained from multiple sources in accordance with the small purchase guidelines. Plan: The District will follow the procedures for the procurement of goods that meet the small purchase procedures as defined by the Uniform Guidance rules. The District will maintain documentation to show that they complied with these requirements. By June 1st of each school year, the Food Service Director will obtain multiple quotes of the food needed to supply breakfast and lunch to all students to ensure that he is obtaining the lowest prices possible for the school district. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Scott Fisher, Superintendent

Management agrees with the recommendation to maintain support for all bids obtained and the conclusions reached as part of the procurement process. The procurement audit sample contained expenses incurred by a Provider Staffing Agency. We were unable to provide support that we obtained multiple bids from staffing agencies. Going forward we will confirm rates via email and maintain the documentation supporting the fact that we are obtaining quotations from an adequate number of qualified sources. In addition, the following actions are being taken: • The Procurement Policy is being sent out to all relevant personnel to remind them of the procedures that must be followed before making purchases greater than $25,000. • Personnel will be required to send in the quotes from the qualified sources at the time the purchase order is submitted. Anticipated date of completion: December 31, 2026

Views of Responsible Officials and Planned Corrective Actions: LHCA acknowledges that in two instances procurement documentation was administratively incomplete. In both cases the underlying competitive process was sound, vendors were evaluated, the appropriate vendor was selected, and the executed contracts reflect those outcomes. No questioned costs were identified. In the first instance, a completed evaluation matrix existed with vendor scoring but did not include a formal notation confirming the award conclusion. LHCA operates in a fully electronic environment where wet signatures are not standard practice. Going forward, documentation systems are in place so that explicit award conclusion notation will be included in the vendor file to make the selection decision self-evident to any reviewer without requiring supplemental explanation.In the second instance, complete procurement documentation existed at the time of the audit but was not delivered to auditors in a timely manner due to staff turnover. This was a document retrieval issue, not a documentation gap. LHCA has addressed this by centralizing all procurement documentation in a shared Google Drive repository that is immediately accessible regardless of staff changes, and by designating a dedicated audit liaison responsible for maintaining and producing all procurement files on request. Going forward, LHCA will incorporate a conflict-of-interest representation clause into all contractor agreements, including the Meat Institute management agreement, effective with the next contract cycle. Annual execution of each contract will serve as the annual conflict of interest certification required under 2 CFR §200.318(c) and LHCA's contracting guidelines, eliminating the need for a separate certification process outside of Executive Board officers involved in procurement. Regarding the market representative relationships. LHCA's market representative relationships were competitively awarded at inception, and are maintained through annual performance evaluation consistent with MAP §1485.29(d)(5), which explicitly replaces periodic re-competition with annual performance evaluation for the life of the relationship. Where a market representative engaged under MAP takes on additional related work funded under other programs such as FMD, the regulatory framework supports an approach other than a new competitive RFP. MAP §1485.29(d)(5) establishes that market representative relationships are not subject to periodic re-competition by virtue of their specialized and relational nature. FMD §1484.35 requires documented price reasonableness but does not prescribe the specific mechanism. 2 CFR §200.320, which applies to both programs by incorporation, recognizes that noncompetitive procurement is appropriate where only one source is reasonably available. Taken together, these provisions support the conclusion that where an existing market representative is the only practicable source for incremental related work — by virtue of their established relationships, market knowledge, commodity expertise, and program continuity — a formal proposal-based review process satisfies the regulatory intent without requiring a competitive process that would produce no meaningful competition. LHCA therefore requires the market representative to submit a formal written proposal for any expanded scope, with deliverables, timelines, and line-item costs sufficient to support a documented price reasonableness analysis. A contract amendment is executed only upon a determination that the proposed scope and cost represent reasonable value. This satisfies the regulatory intent of MAP §1485.29(d)(5), FMD §1484.35, and 2 CFR §200.320 without requiring a competitive process contrary to program interests. LHCA will incorporate this procedure explicitly into its contracting guidelines to ensure consistent application and clear documentation of the policy basis going forward.

Procurement and Suspension and Debarment The College acknowledges the finding and recognizes the need for additional improvements to ensure full compliance with federal procurement regulations. Moving forward, procurement procedures will be strengthened by incorporating vendor eligibility verification requirements, including review of SAM.gov prior to contract execution or purchase approval. The college will also implement recurring training and oversight measures for employees involved in procurement activities to improve adherence to federal standards and internal procedures.

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges that this finding was reported in 2022 and was repeated in FY2023. The College agrees that certain procurement transactions were not adequately supported with sufficient documentation to demonstrate compliance with procurement requirements, including vendor quotations, sole source justification, and procurement history documentation. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, sole source justification, quotations, and bid evaluations. In addition, newly hired Procurement and Accounts Payable staff have been assigned responsibilities for monitoring compliance, a staff training on federal procurement requirements and documentation standards will continue periodically to strengthen oversight and prevent recurrence.

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when racticable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Sherilynn Madraisau Director Bureau of Public Health & Human Services Contact: 680-488-2552 Email: Sherilynn.madraisau@palauhealth.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Ida R. Kilcullen Director Bureau of Curriculum & Instruction Ministry of Education Contact: 680-488-2547 Email: ikilcullen@palauschools.org Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

Planned Corrective Action: We concur with the finding. Management has issued guidance to obtain at least two quotes when practicable. Procurement procedures are being reviewed to strengthen competition, and staff will retain date-stamped SAM.gov screenshots to document suspension and debarment checks before awards. Proposed Completion Date: On-going Name and Contact of Responsible Person: Gail Rengiil Director Bureau of National Treasury Ministry of Finance Contact:680-767-2561 Email: gailr@palaugov.org

The following is Management’s Response to the Findings Required to be Reported by the Uniform Guidance. This document was prepared by management of the Catholic Charities of the Archdiocese of Oklahoma City (“CCAOKC”). 2023-002 Assistance Listing Number 93.576, Refugee and Entrant Assistance Discretionary Grants, U.S. Department of Health and Human Services, FAIN 90RP0121, Award Year 2023, Passed Through by the United States Conference of Catholic Bishops Criteria or Specific Requirement – Procurement, Suspension, and Debarment – 2 CFR § 200.317–.327; 2 CFR § 200.214 Finding Summary CCAOKC’s procurement documentation procedures were not adequate to meet the requirements of 2 CFR § 200.317–.327; 2 CFR § 200.214 - Procurement, Suspension, and Debarment. Explanation of Agreement/Disagreement: Management concurs with the findings and has updated CCAOKC’s procurement policy. Officials Responsible for Ensuring Corrective Action: David Ashton, Sr Director of Administration; E-mail – dashton@ccaokc.org Alan Lipps, Chief Financial Officer; E-mail – alipps@ccaokc.org Planned Completion for Corrective Action: Corrective action completed in FY 2026 Action in response to finding: Purchasing staff are trained in federal procurement requirements and were provided with a copy of the new policy.

2023-003 Procurement Policy Recommendation: Auditors recommend that CIES create a procurement policy and procedures to ensure that all required procurements are performed in accordance with the guidance and criteria outlined above. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: CIES will develop a procurement policy and procedures that ensure all required procurements are performed in accordance with the criteria identified. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: May 2026

FINDING 2023-004 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Completion Date: June 2026

Cause: While policies were in place, detailed written procedures for consistent grant administration had not been developed or formally documented. Corrective Action Taken: A procedure manual has been written to incorporate required compliance areas, including allowability of costs, procurement, equipment management, cash management, time and effort reporting, suspension and debarment, and record retention. Planned Corrective Actions / Preventive Measures: 1. Procedure Development: Document clear written procedures including requisitioning, approvals, reimbursements, reporting, and monitoring. 2. Training and Implementation: Provide training to all staff involved in grant administration on the new procedures. Establish a schedule for periodic refresher training and updates when regulations or program requirements change. 3. Ongoing Monitoring: Designate the Business Administrator (or designee) to monitor compliance and review procedures annually. Update policies and procedures as needed to reflect changes in federal requirements or internal practices. Timeline: Procedures completed: September 2024. Staff training and implementation: June 2026. Ongoing monitoring: Annually, beginning March 2026 Responsible Parties: Lori Schmidt, Business Administrator: Oversight of policy and procedure revision, implementation, and monitoring. Scott LaFortune, Finance Manager/Grant Manager: Day-to-day adherence to procedures and reporting. School Board: Formal policy approval.

Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2022-003) and current year renumbered recommendation (2023-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h); and development of a comprehensive HRSA group of related policies and procedures. A. Financial Policies – May 2025. While the Organization initially prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024, by May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Simultaneous to the policy work described above, several processes to guide and align procurement practices, throughout the Organization, was initiated, including the use of MTPF, Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal, and to date implementation of the processes continue. C. HRSA Policies – July 2025. By July 2025, the Organization developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. In August 2025, the Board was provided policies developed within the Organization’s policy framework, including the above policies. The current practices of the Organization, to the present period of the report dated March 2, 2026, is consistent with such developed policies.

The department will adopt written policies with the Uniform Guidance for Federally Funded Grant Programs accepted by the department.

FA 2023-001 Improve/Strengthen Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Year Finding: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.371C - Comprehensive Literacy Development S371C190016-19A (Years: 2017-21) $124,399.84 FA 2022-002 Description: A review of expenditures and journal entries charged to the Comprehensive Literacy Development program revealed that the School District's internal control procedures were not operating to ensure that appropriate reviews and approvals occurred and the School District's procurement procedures were followed. Corrective Action Plans: The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Dr. Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

Corrective Actions Planned To address the deficiency in internal controls over compliance with respect to procurement, CHC will implement the following corrective actions: CHC will develop and implement a written procurement policy that conforms to the Uniform Guidance.; CHC will ensure sta􀀁 receive adequate training on the procurement policy and the required methods of procurement to be made when making procurements with federal awards. Responsible Person(s): CHC President, Rob Dibble as Primary; CHC Vice President Betsy Gordon as Backup Corrective Action Plan Dates: Schedule implementation starts: February 1, 2026; Staff training starts: March 1, 2026; Review process in effect starts: April 1, 2026

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

Personnel Responsible for Corrective Action: Eljana Kaziaj, Controller Anticipated Completion Date: ASAP. Goal Date is August 31, 2025 Corrective Action Plan: Management accepts the recommendation. It will modify and strengthen our policy and procedure regarding the procurement process to reflect the alignment with federal regulations. Will also maintain a suspension and debarment on vendors. The list will be reviewed monthly.

Management acknowledges this finding, which occurred during a period of rapid program expansion when procurement infrastructure had not yet been fully developed. Since the audit period, we have completely overhauled our procurement process to ensure full compliance with the Federal procurement standards. We have implemented a formal procurement policy, created a dedicated Procurement sub-department within Finance, hired a Procurement Supervisor and support team, and launched a new procurement software platform to ensure proper solicitation, documentation, approval routing, and record retention for all Federally funded programs. These upgrades establish consistent competitive bidding, justification procedures, conflict-of-interest safeguards, and transparent procurement. In addition, we have strengthened oversight, provided staff training on Federal procurement standards, and embedded monitoring practices to ensure ongoing compliance. Management is confident these substantial structural improvements have significantly reduced the risk of noncompliance and positioned the organization for full alignment with federal procurement standards going forward.