Corrective Action Plans

Procurement – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Review Contract and procurement policies and procedures. • Compare current procurement process and training to the policies and identify areas for correction and improvement. • Update Policies and procedures as needed. • Implement procedures to review vendors on a periodic basis. • Implement procedures and assign responsibility for checking off that procurement documentation exists and is in the vendor folder or designated area. • Retrain staff involved in procurement on updated procedures. • Monitor process and adjust as needed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: January 2027

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

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

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

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

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

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

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

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

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

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

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us

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

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

2025-003 Procurement Corrective action planned: CSV will enforce its procedure policy that all competitive procurement transactions above the micro-purchase threshold, when expenditures are charged to a federal award, must have complete supporting documentation retained for at least four years after final payment, in accordance with 2 CFR 200.320. This will be accomplished by providing training for procurement, finance, and administrative staff on: • Recognizing when a transaction exceeds the threshold. • Collecting and organizing supporting documentation. • Understanding retention periods and storage requirements. The Procurement Manager shall oversee compliance with the threshold and retention requirements. CSV shall conduct periodic audits to: • Review procurement files for completeness and compliance with retention requirements. • Identify gaps or missing documentation and correct them promptly. • Document audit findings and corrective actions. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

FINDINGS—FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Environmental Protection Agency 2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the Village evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The Village is 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: Ryan VanDeWalle, Village Administrator and Melanie Wiskow, Finance Director/Treasurer Planned completion date for corrective action plan: The Village is evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Ryan VanDeWalle, Village Administrator at (715) 359-3660.

We followed 2 CFR 200.320(c)(2). Research expertise is unique and only available from subawardees selected for each specific project. It is a fundamental tenet of research. A competitive bidding process is not envisioned, nor practical when preparing grant submissions. All subawardees and contractors have a written justification and review, along with letters of support in the initial grant application.

Time and Effort - Corrective actions were implemented immediately upon identification of the control weakness and prior to the conclusion of the audit. Time-and-effort certifications were subsequently obtained for the affected employees. In addition, the district has enhanced its payroll adjustment procedures involving federal funds by incorporating an additional checklist item within the approval routing process to ensure required time-and-effort certifications are obtained and documented before payroll adjustments are finalized. Procurement Requirements - The following corrective actions will be taken: • Provide targeted staff training related to Federal procurement requirements, including noncompetitive procurement standards under 2 CFR 200.320. Provide additional training focused on internal controls, procurement documentation requirements, and drafting clear procurement justifications. • Update the district’s sole source/noncompetitive procurement documentation form to specifically incorporate and address the five allowable rationale methods identified under 2 CFR 200.320. • Implement additional internal review procedures to ensure procurement files contain sufficient written justification and support documentation prior to approval and execution.

Personnel Responsible for Corrective Action: Karla Clubine, Chief Executive Officer, David Cichocki, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Planned Corrective Action: Management accepts the recommendation. It will modify and strengthen our policy and procedure regarding the procurement process to reflect the alignment with federal regulations. The Hospital will begin performing and documenting suspension and debarment checks on all vendors/contracts funded with grants in fiscal year 2026.

Finding 2025-003: Procurement, Suspension and Debarment The single audit report included the following recommendation: EY recommends that Amtrak include legal expenses within their procurement, suspension and debarment policy as outlined within each of the grant agreements. Management Response/Status of Action Plans: Pursuant to Section 26(j) of Amtrak’s annual grants, Amtrak’s policy is to fund most law firm engagements with Program Income without applying grant requirements that apply to other procurements. In FY2025, this was the case for all law firm engagements charged to operating activities. Also, in FY2025, Amtrak had a portion of its legal expenditures charged to capital projects based on the nature of the legal work performed. These capital projects were funded with federal grants. For legal expenditures which are by their nature related to projects funded by grants, Amtrak acknowledges the need to have the proper procurement process including competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-down based on the grants. By the end of FY2026, the Law Department will review and update its internal procedures to better prevent recurrence of legal expenditures that did not have proper competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-downs from being charged to projects funded by grants. As part of that review, Amtrak will consider whether it may be appropriate to utilize the Company’s broader procurement policies. The contacts for this item are Lucia Butts, AVP Funding and Grants and Thomas Bloom, Deputy General Counsel and Corporate Secretary. Amtrak anticipates fully remediating this finding by September 2026.

Blood Diseases and Resources Research (ALN 93.839) Recommendation: We recommend that the Organization follows all procurement method requirements for purchases over the $10k micro-purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedure enhancements to its retainment and processing of documentation for simplified acquisition procedures. Including: quotes and other qualified sources documentation is attached to the relevant purchase requisition within our ERP system prior to submission of the requisition for review and approval; a three-step/tiered review and approval process. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: May 2026

This is the result of procurement transactions fonded with the ARPA Coronavirus State and Local Recovery Funds. The County did not conduct procurement transactions in a manner providing fair and open competition on two constrnction contracts. The comptrollers office will enhance procurement policies and review of federal grant funded purchases.

1. The District will no longer use federal funds for special education bussing. 2. The district will submit a separate request for approval for a noncompetitive proposal when procuring with an entity using federal funds to the Department of Education and Workforce.

Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.

Management will improve procurement compliance controls by: • The verification and retention of support that vendors are not suspended or debarred has been moved to be part of the accounts payable onboarding process of vendors and maintained in the vendor’s file in the accounting system. • Implementing a standardized checklist or form documenting that the verification that a vendor has not been suspended or debarred prior to contract execution and/or payment. • Providing refresher training to staff involved in procurement and accounts payable on documentation requirements.