Corrective Action Plans

The University agrees with the finding. Management drafted and formally adopted a Uniform Guidance-compliant procurement policy and SAM.gov policy, and training was provided to all staff. See the separate Corrective Action Plan for full details.

Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors' concerns regarding the retention and availability of historical procurement documentation. However, SWK notes that this finding relates primarily to documentation retention and retrieval rather than a failure to perform procurement activities or suspension and debarment verification. The primary issue resulted from the termination of the Unaccompanied Alien Children (UAC) Program during Fiscal Year 2025, which led to significant organizational downsizing, including the elimination of the Procurement Department. Historical procurement, solicitation, and bid documentation had been maintained within a procurement software platform administered by that department. Following program closure and the departure of procurement personnel, the software platform was decommissioned, resulting in certain historical procurement records no longer being readily accessible during the audit. SWK did, however, provide evidence that vendors selected for procurement actions were screened for suspension and debarment in accordance with federal requirements. Additionally, two of the six contracts exceeding the simplified acquisition threshold represented renewals of previously procured contracts; however, complete historical bid files could not be retrieved for audit review. SWK further notes that as of the date of this corrective action plan: • The UAC Program has been terminated. • SWK no longer maintains a dedicated Procurement Department. • SWK has no active federal procurement contracts over $250,000 requiring formal solicitation procedures. • No questioned costs were identified by the auditors. • The auditors concluded that services and goods purchased under the reviewed contracts were allowable and supported program operations. Corrective Actions Although the circumstances surrounding this finding relate to historical records associated with a discontinued program, SWK has implemented the following actions to strengthen document retention and procurement oversight for any future federally funded procurements: 1. Centralized Procurement Record Retention SWK has established a requirement that all procurement-related documentation, including solicitations, bid responses, evaluations, vendor selection justifications, contract approvals, and suspension/debarment verifications, be maintained in a centralized electronic repository controlled by Finance and Administration, rather than an individual department or software administrator. 2. Procurement Documentation Checklist SWK will continue to utilize a standardized procurement checklist for any future procurement transactions subject to federal procurement requirements. The checklist will ensure required documentation is retained and readily accessible for monitoring or audit purposes. 3. Enhanced Document Archiving Procedures Prior to the discontinuation of any program, department, or software platform, SWK will perform a records-retention review to ensure all procurement and contract documentation subject to federal record retention requirements is archived and preserved. 4. Management Oversight The Chief Administrative Officer will be responsible for periodic reviews of procurement files to verify that required documentation is complete and retained in accordance with federal and organizational requirements. 5. Future Procurements SWK will review and update its documented procurement procedures to conform to applicable federal statutes, the procurement requirements identified in 2 CFR Part 200, and the new federal procurement thresholds as of October 1, 2025. Further, SWK will institute a centralized purchasing function under Finance and Administration to facilitate the review of procurements to ensure compliance with both 2 CFR Part 200 and the terms and conditions of awards. This function will ensure the enforcement of the procedures mentioned above by: - Conducting vetted vendor onboarding and ongoing management via periodic reviews to verify that non-federal entities, contracts, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federal programs - Obtaining appropriate documentation of multiple vendor quotes and/or sole source justification for small purchases greater than the micro-purchase threshold, but below the simplified acquisition threshold - Managing, following, and documenting the simplified acquisition procedures for purchases greater than or equal to the simplified acquisition threshold Expected Completion Date: In process and to be completed by December 31, 2026 Ongoing monitoring and compliance reviews will continue for any future procurement activities. Status Corrective action substantially implemented. Upon review of current FY2026 purchases and due to the closure of the UAC Program, the risk associated with this finding has been significantly reduced. The corrective actions above are designed to ensure appropriate documentation retention and compliance should future federally funded procurement activities occur. Responsible Officials: Chief Administrative Officer, Marisol Cervera

Finding 2025-005: Noncompliance over Procurement Name of Contact: Chris Pallister, Executive Director Corrective Action: Management will establish and maintain written procurement procedures as specified in the Uniform Guidance procurement standards. For purchases and contracts exceeding $50,000 annually the Organization will publish RFP’s on SAM.gov at least 60 days prior to the project start date. The RFP’s will include the following aspects: • Scope of Work (SOW) or Performance Work Statement (PWS): The RFP should clearly define the project objectives, tasks, and expected deliverables. • Instructions to Bidders: Detail how proposals must be formatted, page limits, and precise submission directions. • Evaluation Criteria: State how bids will be scored (e.g., technical approach, past performance, and price weighting). • Federal Provisions: Include required federal clauses (such as Buy American requirements or Uniform Guidance standards. Any proposals received in response to the RFP will be considered. Proposed Completion Date: November 15, 2026.

Finding 2025-006 I. Procurement, Suspension and Debarment Procurement Approval and Executed Agreement Compliance Management agrees with the finding and has outlined the following corrective actions: • Obtain Board approval for a new intergovernmental agreement for Chicago Police Department at the September 2026 board meeting. • Complete a full review of 2025 and 2026 procurement files by the end of Q1-2027 to ensure all required Board approvals and executed agreements are retained. • Strengthen internal workflows to prevent procurement actions from proceeding without verified approvals and executed agreements through inclusion of a new checklist which will be reflected in an updated standard operating procedures (SOP). • Provide refresher training to procurement staff on 2 CFR 200 documentation retention requirements by December 2026. Suspension and Debarment Compliance Management concurs with the findings and will implement: • Semiannual targeted training to reinforce staff responsibilities for verifying vendor eligibility and documenting compliance to begin December 2026. • Enhanced managerial monitoring through a standardized checklist to ensure required suspension/debarment checks are completed and retained before issuing purchase orders. Implemented January 2027. Responsible for Corrective Action: Tamika Carson, Director of Procurement; Sheila Johnson, Deputy Chief Procurement Anticipated Completion Date: Q1-2027

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirements: 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 Health and Human Services None 93.243 - Substance Abuse and Mental Health Services Projects of Regiona l and National Significance 5H79SM088573-02 (Year: 2025) $80,321 A review of expenditures cha rged to the Substance Abuse and Mental Health Services Projects of Regional and National Significance program revea led that the School District's internal control procedures were not operating appropri ately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Procedures have been reviewed with program and department leaders to ensure that all expenditures have proper approval before submitt ing for payment. Expenditures without proper approval will be returned to the responsible department. Board Policy DJED has been reviewed with all department heads to ensu re understanding of policy and requirements for obtaining multiple quotes for certain thresholds. Additional procedures will be added to how vendors are verified of being suspended or debarred. Currently the vendor is verified of not being suspended or debarred when they are added to the accounting system and then once annually if they have been paid $25,000 or more during a certain time frame. Additional procedures will be added to have the vendors verified at year end who have been paid $25,000 or more with federal fun ds. Estimated Completion Date: August 31, 2026 Contact Person: Stephanie Clark, Chief Financial Officer Telephone: 912-876-4854 Email: sclark@liberty.k12.ga.us

FA 2025-002 Improve Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Description: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agricu lture Georgia Department of Education 10.553 - School Breakfast Program; 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $40,701 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 expenditures were appropriately reviewed, approved, and documented. Corrective Action Plans: Procedures have been reviewed with program and department leaders to ensure that all expenditures have proper approval before submitting for payment. Expenditures without proper approval will be returned to the responsible department. Board Policy DJED has been reviewed with all department heads to ensure understanding of policy and requirements for obtaining mult iple quotes for certain thresholds. Guidelines have been reviewed with the program manager and school nutrition bookkeeper to ensure all expenditures are recorded in the correct fiscal years. Estimated Completion Date: August 31, 2026 Contact Person: Stephanie Clark, Chief Financial Officer Telephone: 912-876-4854 Email: sclark@liberty.k12.ga.us

Audit Finding Reference: 2025-003 Special Education Planned Corrective Action: For all special education procurements, a formal sole source justification statement will be documented and retained with the purchase records. Planned Implementation Date of Corrective Action: School year 2026-2027 Persons Responsible for Corrective Action: Ronnie Kessler, Director of Student Services Director Kirsteen Patterson, Director of Finance and Operations

Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.

Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges 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). The Organization concurs with the prior year (2024-003) and current year renumbered recommendation (2025-003),and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Financial Policies – May 2025. 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. Initiated use of MTPF, and process implementation of Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal. C. HRSA Policies – July 2025. 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. Informed the Board about the progress of the Organization’s policy framework, including the above policies. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the application of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). E. Updated procurement processes for emergency disaster recovery and support of community needs, including MTF documentation. Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date Finding No. 2025-003: Procurement Policies Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.

Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.

Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importance of complying with its purchasing and procurement policies.

Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 audit occurred before the corrective measures became effective. Corrective measures implemented include policies and procedures designed to strengthen its procurement and contracting processes. These include: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work Management believes these corrective actions address the deficiencies identified and expects them to be fully effective for construction activities occurring after implementation.

Emergency Solutions Grant – Assistance Listing No. 14.231 Recommendation: We recommend that management implement formal procurement policies requiring periodic reassessment of vendors used in federally funded programs, particularly when new grant awards are received or grant periods change. This should include evaluating whether the original procurement method remains appropriate, performing updated cost or price analyses as necessary, and conducting and documenting periodic suspension and debarment checks (e.g., SAM verification). Additionally, management should establish oversight controls to ensure procurement compliance and vendor eligibility are maintained throughout the lifecycle of vendor relationships in accordance with 2 CFR §200.318–200.320 and §200.214. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Avivo is in the process of updating its procurement policy and processes to include annual reviews of ongoing vendor contracts that will assess the appropriateness of the original procurement conditions and determine if updates or new analyses are required. Reviews will be signed off by the staff with contracting authority at the time of review; and if warranted, the appropriate staff will undertake new cost analyses, complete the documentation, and save in a shared repository that relevant departments will have access to. Program leadership is working with the appropriate administrative departments to develop the necessary processes for periodic review and the collection/storage of documentation around the periodic review process. The Accounting department has added a system-wide debarment check of all active vendors in the 3rd quarter of each year and will add any new vendors to this schedule regardless of when they were originally added to the vendor payment system. This ensures that all vendors are re-checked for debarment and suspension at minimum of one time annually. Name(s) of the contact person(s) responsible for corrective action: Kelly Matter Planned completion date for corrective action plan: 12/31/2026

Management concurs that a formal written procurement policy was not in place during the FY2025 audit period. Procurement activities were governed by established operational practices during FY2025, and a formal Procurement & Contract Administration Policy was adopted and implemented in March 2026. The policy establishes procurement methods, approval requirements, documentation standards, conflict-of-interest requirements, and procedures for noncompetitive procurements. Anticipated Completion Date: March 2026. Responsible Contact Person: Michael Quan, Director of Finance & Operations.

BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026

Management acknowledges that procurement documentation was not consistently maintained during the audit period. Because the FY2024 audit was completed after the FY2025 fiscal year had ended, management did not have an opportunity to implement the prior-year corrective actions in time to affect the FY2025 audit period. Since the audit period, the Organization has strengthened procurement and compliance oversight by elevating the Director of Programs position to Vice President of Programs in September 2025, launching the Compliance and Risk Management Committee in FY2026, and creating a Compliance & Evaluation Manager position with an anticipated start date in August 2026. Fiscal and program leadership have substantially revised the procurement policy and are developing related procedures and standardized documentation requirements. The policy and procedures will be reviewed by the Compliance and Risk Management Committee in early FY2027 before being submitted for Board approval. The revised materials address competitive quotations and bids, vendor selection, price reasonableness, noncompetitive procurement justifications, conflict-of-interest requirements, debarment verification, and documentation of the procurement history. The FY2027 budget includes 2 CFR Part 200 training for Fiscal, Programs, and Grants staff. Blackbaud Financial Edge, scheduled to go live in FY2027, will further support approval workflows, transaction tracking, role-based access, and document retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken • Elevated the Director of Programs position to Vice President of Programs in September 2025. • Launched the Compliance and Risk Management Committee in FY2026. • Created a Compliance & Evaluation Manager position, with an anticipated start date in August 2026. • Strengthened supervisory review and reinforced procurement documentation expectations. • Substantially revised the procurement policy and began developing standardized procedures and documentation requirements. • Scheduled Compliance and Risk Management Committee review of the revised policy and procedures for the fall of 2026. • Included 2 CFR Part 200 training for Fiscal, Programs, and Grants staff in the FY2027 budget. • Initiated implementation of Blackbaud Financial Edge; planned go-live for October 2026.

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.

2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The City immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Kassandra Paider, Finance Director Planned completion date for corrective action plan: The City immediately began evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Kassandra Paider, Finance Director, at (920) 793-7274.

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE

NNEDV management and the finance team have reviewed the current policies regarding sole-source procurement. NNEDV’s leadership team has received training on procurement requirements and the policy manual will be updated to ensure NNEDV’s procurement policy is in line with 2 CFC 200. Anticipated Completion Date: 7/31/2026, Responsible Contact Person: Ellen Yin-Wycoff, Assistant VP of Programs & Operations.

Lima City Schools has procurement policies and procedures in place and will ensure that all contracts entered into for purchased services will be sure to follow the board approved procurement policies and procedures. The Lima City Schools will establish appropriate controls to ensure there is no overpayment. The board will obtain appropriate price quotes and non-competitive proposals and verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

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