Corrective Action Plans

Audit Finding Reference: 2025-003 Planned Corrective Action: The Special Education and Student Support department will immediately ensure complete implementation of our existing sole source procurement protocols. For any purchase that requires competitive procurement, we will conduct relevant market research and obtain multiple quotes, or depending on the amount, engage in an RFP process. We will only engage in sole source procurement when we have determined that there is only a single provider of the good or service, and we will document that determination appropriately. All staff in the department who engage in our purchasing process will be retrained in these protocols, and will be expected to implement them going forward. The head of the department will review all proposed purchases to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 30, 2026 Person Responsible for Corrective Action: Jesse Applegate, Senior Director of Special Education and Student Support

Audit Finding Reference: 2025-004 Improve Procurement Process for Child Nutrition Cluster Planned Corrective Action: The Portland Public Schools Child Nutrition Department will begin the process on March 16, 2026, to obtain a third vendor for small purchases. This action will ensure fair and equitable competition among vendors. The department will work with the Maine Department of Education Child Nutrition Program and Portland Public Schools to ensure full compliance with all procurement requirements. The Food Service Department will create procedures with vendors that supply goods to our program. Implementation of these contracts will begin as soon as a formal decision is made in coordination with the District's Purchasing Manager and the City of Portland. Planned Implementation Date of Corrective Action: 3/17/2025 Person Responsible for Corrective Action: Tyler Guerin, Food Service Director

2025-002 Procurement Supporting Documentation Planned Corrective Action Plan: Heartwood will review federal grant requirements then will ensure that policies and procedures are in compliance with those requirements. Finally, documentation obtained during required procedures, will be centrally located to demonstrate compliance. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Sherri Sampson, Executive Director

March, 3, 2026 U.S. Department of Health and Human Services Dimock Community Foundation, Inc. and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc., 50 Washington Street, Westborough, MA 01581 Audit period: July 1, 2024 - June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD FINDING Material Instance of Non-Compliance: Finding 2025-001: Congressional Directives 2025-001 Assistance Listing Number 93.493 Community Project Funding/CDS Recommendation: We recommend that the Agency adhere to their procurement policy that aligns with the requirments set forth in 2 CFR 200.318-200.326 Action Taken: The procurement of construction services funded through this award was done in early 2023 and preceded Dimock's updated procurement policy which calls for competitive bidding. It also preceded changes in procurement leadership. Subsequent procurement for services have since been subject to competitive bidding by Dimock consistent with CFR 200.318-200.326. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call Luis Rivera, CFO at 617-442-8800. Sincerely, Luis Rivera, CFO

Management will strengthen procurement controls to ensure compliance with 2 CFR 200.320 for noncompetitive procurements. • Policy Update: Create addendum to procurement policies for current HUD federal requirements to include criteria for allowable sole-source procurements. This will be to support any future procurement with federal funds. • Justification Requirement: Require documented justification demonstrating that one of the allowable criteria under 2 CFR 200.320(c) is met for all noncompetitive procurements. • Approval Controls: Require prior review and approval of sole-source procurements by designated management. • Training: Prior to next Federal Grant requiring a single audit, provide training to staff on federal procurement requirements. • Documentation: Maintain complete procurement files, including justification and approvals.

Management will follow procedures as outlined in its policies and procedures to ensure all stages of the process adequately conducted and documented.

All Federal purchases based upon current board policy ($10,000) quotes will be obtained and submitted with the requisition. This will now include purchased services as well as supplies and equipment.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

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

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding: Procurement methods did not always follow Uniform Guidance requirements. Contracts were directly awarded to vendors without full and open competition or obtaining price or rate quotations from an adequate number of qualified sources. Auditor Recommendation: The County should provide training to staff regarding Uniform Guidance rules of procurement and how to identify which contracts support federal award programs. Corrective Actions Taken or Planned: The County agrees and concurs. The County anticipates providing more training to grant program managers and additional reviews during FY26 as the program closes out. Point of Contact for corrective actions: Sarah Keane, Deputy CFO sarah_keane@washingtoncountyor.gov

FINDING 2025-005 – Procurement, Suspension, and Debarment (Partially Repeated from Prior Year Finding 2024-002) Audit Finding Description: For fourteen (14) out of fourteen (14) procurement transactions tested related to procurement and suspension and debarment compliance, the following was noted: 1. The Inner Voice, Inc. did not complete the appropriate procurement process. 2. The Inner Voice, Inc. did not maintain appropriate documentation to support the procurement method utilized. 3. The Inner Voice, Inc. did not maintain documentation evidencing that suspension and debarment searches were performed. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Corrective Action Plan: Management will review procurement policies and procedures to align with Uniform Guidance requirements. This will include documentation of procurement methods, adherence to competitive procurement standards, and verification of suspension and debarment status. Management will also provide training to concerned staff to ensure consistent implementation of the updated policies. Name of Contact Person Responsible for Corrective Action: Diana Mitchell, CPO / Khurram Navaid, CFO Planned Completion Date: March 01, 2026

FINDING 2025-004 Finding Subject: Special Education Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district will implement procedures for Procurement, Suspension and Debarment by following the listed steps: 1. Three quotes will be obtained for procurements between $50,000 to $150,000 by the district and contract be awarded. 2. Verification of Suspension and Debarment will be performed by a member of the business office in System for Award Management (SAM) or the district will collect the certification from the entity prior to entering into transactions with the selected entity. Anticipated Completion Date: 3/31/2026

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA)- Procurement and Suspension and Debarment Federal Agency: Department of Education Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Procurement and Suspension and Debarment compliance requirements. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: We will establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: June 30, 2026

Finding 2025-004 Internal Controls over Procurement Plan: The enhancement to the e-procurement system to ensure appropriate documentation is captured in the central procurement file was implemented in June 2025. Implementation Date: June 15, 2025 Contact: Aaron Rosenthal, Assistant Vice Chancellor Purchasing and Contract Management University of Illinois Chicago Aaronr1@uillinois.edu 312-996-8074 Bradley Henson, Director of Purchasing Purchasing and Contract Management University of Illinois Urbana-Champaign Bhenson4@uillinois.edu 217-300-2459

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

2025-004-Procurcmcnt Suspension and Debarment We have developed an internal form that each employee knows they must fill out when obtaining any kind of service or supply. We have educated staff on the dollar limits and thresholds required as well as any backup documentation needed to be obtained for each purchase of goods or services. Moving forward the finance department will be responsible for running sam.gov checks to make sure all vendors that the district does business with are clear of suspension and debarment at either the start of the fiscal year or whenever procuring new services and goods throughout the year.

Date: February 9, 2026 FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Paula Powers, Food Service Coordinator Contact Phone Number and Email Address: 812-347-3905 ppowers@nhcs.k12.in.us Views or Responsible Official: We concur with the findings. Description of Corrective Active Plan: The Food Service Coordinator will verify Sam.gov to confirm a contractor is not suspended or disbarred before awarding a contract every 12 months. For small purchases, quotes will be obtained and retained with the claims for that payment. Anticipated Completion Date: March 2026

Information on the federal program: Subject: Child Nutrition Cluster, Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: Child Nutrition Cluster Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micropurchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not review procurements done by the food service management company to ensure that proper procurement policies were followed. The School Corporation did not ensure that the food service management company did not use suspended or debarred vendors. During the audit period, we noted two small purchases for which the School Corporation did not have evidence of obtaining multiple quotes or documented rationale for selecting the vendor. Only the final invoice, purchase order, and quote from the selected vendor were available. During fiscal year 2024, we noted that for one of the three vendors tested, the correct procurement method was not followed. Purchases from the vendor were in excess of $150,000 during the fiscal year, requiring the simplified acquisition procurement process; however, the School Corporation applied the small purchase procurement process. The purchase was for equipment at two different buildings. The School Corporation issued two requests for quotes, one for each school, and treated them as separate procurements. However, as the purchases were similar in nature, the requests for quotes were dated the same day and sent to the same vendor, this should have been treated as one procurement in aggregate. The School Corporation did not have support for public advertisement, requests for formal sealed bids, or formal documentation for the basis of award. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, we noted two vendors out of three that were sampled, over the $25,000 suspension and debarment threshold for which the School Corporation did not have evidence of a suspension and debarment check. Views of Responsible Officials: Management agrees with the finding and has prepared a corrective action plan. Description of Corrective Action Plan: Management will review procurements done by the food service management company. Management will also ensure that appropriate procurement processes are followed for all future purchases and suspension and debarment checks are completed for purchases over $25,000. Responsible Party and Timeline for Completion: The Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

Procurement policies and procedures were being updated to include clearer direction for documenting purchases, including a strengthened retention policy for procurement documentation. This was implemented at year end but was not present for the transactions during the year.

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) INDIANA STATE BOARD OF ACCOUNTS 36 Lakeland School Corporation 0825 E 075 N, LaGrange IN 46761 Phone: (260) 499 - 2400 Fax: (260) 463 - 4800 ______________________________________________________________________________________________ Educating and preparing ALL students for career & life success! Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5- 22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: The projected date of completion is March 31, 2026.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

Finding 2025-002 - Procurement - Noncompliance with Formal Competitive Requirements Noncompliance & Significant Deficiency Moving to Work Demonstration - ALN #14.881 Corrective Action Plan: SCRHA3 will review operating practices to ensure alignment with Federal Regulations and its procurement policy. This will include assigning a Procurement Officer to oversee the procurement process and verify all procedures are followed for procurements based on the policy, defining staff roles and providing necessary training to personnel involved in procurement. The Housing Authority will develop a process that a procurement requester must complete & submit the procurement to the Procurement Officer for review and approval. Person Responsible: Richard Brockington (Director of Development) Anticipated Completion Date: No later than end of first quarter of 2026 - March 31, 2026.

Material Weakness in Internal Control over Compliance and Compliance 2025-001 Procurement, Suspension, and Debarment. Criteria The District is required to maintain and use documented procurement procedures for procurement transactions under federal awards. Noncompetitive procurement (sole source) may be used if specific circumstances in the Uniform Guidance are met. Statement of Condition The District procured IDEA services through the LIU using a noncompetitive (sole source) approach. The District did not retain documentation in the procurement file to support the basis for noncompetitive procurement. Statement of Cause The District did not consistently follow documented procurement procedures for the IDEA program and the procedures. Possible Asserted Effect Without documentation supporting the noncompetitive procurement method, the District is not able to demonstrate compliance with federal procurement requirements applicable to IDEA. Questioned Costs None noted. Context One vendor was utilized and there was not appropriate documentation maintained of procurement regarding the services. Repeat Finding This is not a repeat finding. Recommendation We recommend that a process be implemented to review the services provided under the IDEA program to ensure procurement documentation is appropriately maintained. Views of responsible officials and planned corrective action To ensure compliance with this standard in the future, the Assistant to the Chief Financial and Operations Officer will provide the Director of Special Education and the Superintendent with the Sole Source Justification form by July 1st of each year. The Director of Special Education and the Superintendent will be responsible for completing the Sole Source Justification form and submitting a copy of the signed document to the Business Office. The Special Education Financial Secretary will attach the Sole Source Justification form to the purchase requisition for services from the Franklin Learning Center for the IDEA-qualified students.