Corrective Action Plans

Audit Finding Item 2024-001 Corrective Action Taken: In response to this finding, Tulsa Cares is developing and will formally adopt written procurement policies and procedures in alignment with the requirements outlined in 2 CFR 200.318(a). These policies will establish standards of conduct, ensure full and open competition, and provide clear guidance for the procurement of goods and services under federal awards. This corrective action will be completed by the next board meeting, scheduled for December 4, 2025. Responsible Party: Natalie Jarred, Chief Financial and Administrative Officer, is responsible for monitoring compliance with procurement policies and updating them as necessary.

Views of Responsible Officials and Planned Corrective Actions: At the time of the transactions in question, the Organization operated under the understanding that multiple bids were required only for costs exceeding $50,000. The Organization was then provided updated guidance from our audit firm indicating that the correct threshold was $10,000. This shift demonstrates the complexity of interpreting and applying procurement rules. Since the beginning of the grant, the Organization has actively researched and sought clarification on the applicable purchasing and contracting requirements. Unfortunately, different sources provided conflicting thresholds and requirements. Based on the information available at the time, the Organization made a deliberate and well-reasoned decision not to seek multiple bids for certain expenditures. The grant funding source received full documentation for these costs, did not raise concerns, and reimbursed the expenses without issue. The Organization acted in good faith and in alignment with the guidance it had at the time of these purchases. To address this finding the Organization has implemented a revised procurement policy requiring multiple bids or sole source rationale for any purchases exceeding $10,000. Staff have been made aware of this threshold, and procedures are in place to ensure compliance moving forward.

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 Health System is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Health System will create a procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include 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 to demonstrate compliance with 2 CFR section 200.318 through 200.327. Contact Person: Daniel Cooper, Vice President of Finance and Accounting Expected Completion Date: December 31, 2025

Management will continue strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. Purchase orders will no longer be included in any submissions. Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained.

Views of Responsible Officials and Planned Corrective Actions: Management reviewed its Procurement policy and procedures and found there was a lack of competitive quote documentation for purchases under $100k. Management has updated its procurement procedures to include the addition of a Procurement Form. The procurement form is meant to be a high-level checklist where staff must state the price of the good/service being purchased and attach sufficient documentation of quotes from multiple vendors so AAM can ensure its limited resources are being best utilized. Purchases over $100k must include the utilized RFP, received proposals, and analysis of vendor offerings and credentials. Staff must now complete and sign this procurement form and submit it to Finance for final signature and approval. This added Procurement Form and check-and-balance will help ensure that AAM Staff understand their purchasing responsibilities and work to keep the organization in compliance.

Management will develop and implement a procurement policy for federal awards that aligns with federal requirements including setting thresholds based on aggregate dollar amounts of procurement transactions. This policy will include requirements for the retention of price comparisons or quotes and decision-making.

IN 2025, REVIEWS WERE PUT INTO PLACE TO ANALYZE IF A PROJECT WOULD MEET FEDERAL COMPLIANCE REQUIREMENTS WHEN FUNDING SOURCES ARE BEING DETERMINED. FOR FUTURE PROJECTS, IF FEDERAL FUNDING WILL BE USED ON A PROJECT AFTER CONSTRUCTION BEGINS, WE WILL REASSESS TO DETERMINE IF COMPETITIVE BIDDING IS FEASIBLE.

FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings of this report. Description of Corrective Action Plan: The County Highway Department has implemented a new filing system to help ensure that audit documentation is being maintained for all federal requirements. The County will maintain documentation of all bids and Letter of Interests (LOIs) received from vendors for each project for review. These files are maintained in their own folder with the DES# and project description on the outside. The County will also maintain documentation of the LPA Selection Review Checklist for each project for review. The County Highway Superintendent is responsible for maintaining all the files and the administrator will review/sign the checklist to ensure all the files are properly maintained. In addition, the County is currently working with the County's attorney to develop a procurement policy that includes federal regulations. Anticipated Completion Date: September 2025

FINDING 2024-004: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The town attorney will draft a standard contract that will apply to any contractors that are paid $25,000.00 or more from federal funds, prior to entering a covered transaction ensuring that their respective contractor is not suspended or debarred. The council president will review and sign the contract ensuring the suspension and debarment clause is included in all respective contracts. The town has put controls and procedures in place to ensure timely documentation of suspension and debarment checks in regard to federal awards. For purchases procured outside of a contractual agreement, the town will require all vendors to self certify prior to entering into a transaction. The town will implement a procurement policy that conforms to the current requirements of CFR 200.318 for micro-purchases, under $10,000.00, the disbursing officer will only require board approval. For small purchases, between $10,000.00 and $150,000.00, three quotes must be obtained and a contract awarded. For purchases that exceed the simplified acquisition threshold, the town must allow for full and open competition in the form of a sealed bid process and awarding a contract. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

Condition: During our testing, we identified two contracts that did not have adequate documentation to support the basis for the contract price. Planned Corrective Action: Effective 6/1/2025, TARTA implemented a new ERP system that will allow us to electronically control and verify all purchases in accordance with 2 CFR 200.32 standards for acceptable methods of procurement going forward. Contact person responsible for corrective action: James Karasek Anticipated Completion Date: 6/1/2025

FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has a longstanding contractual relationship with an engineering firm with extensive knowledge of the City’s water department. The city has put controls and procedures in place to ensure services are bid where federal awards are involved and the dollar amount of such services is expected to exceed the simplified acquisition threshold. The City will review its procurement policy and amend where necessary to conform to the current requirements of CFR 200.318. The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. Anticipated Completion Date: January 1, 2026

Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original intergovernmental agreement (IGA) and determined that the agreement had not expired and required no additional board approval or agreement. This is why each year since, Legal has provided authorization for purchase order creation and payment to Chicago Police Department (CPD). The agency is working with CPD to formalize a new IGA. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025

CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2024 Identifying Number: 2024-001 Finding: During testing of a sample micro-purchase transactions, transactions were identified that lacked contemporaneous documentation supporting a reasonable price determination. From the sample of 40 micro-purchase transactions, half lacked proper contemporaneous documentation supporting a reasonable price determination. Proper approvals were sited for any vendor agreements, invoices, and journal entries as applicable noting due diligence was performed. Corrective Actions Taken: In FY25, IRI revised the process for price justification documents related to micro-purchases. These documents must now be attached to the AP bill in JAMIS (previously, program teams maintained them in their own folders), ensuring that all supporting documentation is stored electronically alongside each transaction. In addition, IRI is rolling out the online contractual system Agiloft, through which all contracts and supporting documents for micro-purchases will be processed electronically, making them easily accessible for review and amendments. Contact Person(s): Procurement and Finance teams: Jessie Ash and Vitaliy Fesun Global Operations team: Brian Zupruk Person Responsible: Vitaliy Fesun, Director of Finance Anticipated Completion Date: October 01, 2025

Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends regular review of the Organization's procurement policies to ensure they continue to meet procurement standards, as set by Uniform Guidance, and they continue to be consistently implemented. CLA also recommends reviewing internal controls surrounding procurements to ensure they are sufficient to prevent noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previous corrective actions were completed in April 2024 upon receipt of our FY 2022 audit and further amended in August 2024 during FY 2023 audit to update internal procurement policies to match Uniform Guidance requirements. We believe these corrective actions would have captured most, if not all, of the incidents in February and March 2024 that contributed to this repeat finding. That said we will continue to regularly review the Organization’s procurement policies to ensure they meet procurement standards. We also aim to implement an annual internal control review to ensure they are sufficient to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/01/2025

Corrective action plan: Management believes that the procurement process has improved considerably. Managers are following the procurement policy by making price comparisons and submitting quotes when required. Approvals for larger purchases are obtained by Resolution from Council. The Finance Manager and the Accounts Payable Clerk monitor the documents submitted with purchase requests to ensure that the required documents have been submitted. Management believes that it is an isolated instance where a transaction lacked procurement documentation. Personnel responsible for corrective action: Lisa Donham (Finance Manager), Deidre Moyle (Accounts Payable), and Program Managers. Estimated corrective action completion date: December 31, 2025

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, reporting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

Coronavirus Relief Funds – Assistance Listing No. 21.027 Recommendation: CLA recommends the County review and follow their procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Dickinson County will follow their procurement policy related to federal awards. Name of the contact person responsible for corrective action: Brian Bousley, Controller/Administrator Planned completion date for corrective action plan: December 31, 2024

Corrective action planned – Management recognizes that procurement is a material concern of the organization both from an operational efficiency and regulatory compliance perspective. During the audited time period, procurement responsibilities were decentralized, resulting in inconsistent compliance. In April 2025, Management decided to create a dedicated Procurement Department and began staffing the department. The new Procurement team is tasked with reviewing all current procurement policies and procedures, revising and creating new processes as needed, and partnering with the compliance team to monitor compliance going forward. The policy and procedure revisions will be implemented by the end of the fourth quarter of 2025. Staff will receive training by the first quarter of 2026, and after the training rollout, we will begin internal audits to ensure successful training, implementation and compliance with the new policies and procedures. Name(s) of contact person(s) responsible for corrective action – Alison Spens, Senior Director of Project Management and Procurement Anticipated completion date – August 15, 2025

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 will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include 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 to demonstrate compliance 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 contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

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 will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include 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 to demonstrate compliance 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 contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

The Board of Health will adopt updated written policies periodically in accordance with the Uniform Guidance to help improve internal controls over federal compliance for the findings listed in this number.

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA adopted a new, updated procurement policy in October 2024. PDA worked with Clark Nuber to develop this policy. Anticipated Completion Date: October of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 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 expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The following corrective actions will be implemented by the School District: 1. Implement Strengthened Pre-Approval and Documentation Procedures: a. All Child Nutrition purchases will require a completed purchase request form that clearly identifies the funding source, purpose, and allowability under federal guidelines. b. Documentation (invoices, quotes, purchase orders) must be attached and reviewed by the School Nutrition Director and CFO or designee before approval. 2. Enhance Segregation of Duties: a. The individual initiating a purchase or expenditure will not be the same person approving or reconciling it. b. Monthly expenditure reviews will be performed jointly by the Finance Department and School Nutrition leadership to ensure accuracy and compliance. 3. Establish an Internal Monitoring Checklist: a. The School Nutrition Department will implement a monthly internal monitoring checklist that includes documentation review, reconciliation of expenditures, and verification of procurement compliance. The CFO will meet with the Nutrition director monthly. 4. Update Written Polices and Procedures: a. The district's Financial Procedures Manual and the School Nutrition Operations Manual will be updated by December 2025 to reflect all new internal control steps and approval requirements specific to federal expenditures. Estimated Completion Date: June 30, 2026 Contact Person: Tiffany Crockett, Chief Financial Officer Telephone: 478-946-5521 Email: tiffany.crockett@wilkinson.k12.ga.us

Reference: 2024-003 Corrective Action: The City will work on updating the procurement policy to include clearer expectations. Responsible Person: Kristopher Hanus Frederickson, Mayor; Patrick Reagan, City Administrator; Wendi Bixby, Finance Director/Treasurer Anticipated Completion Date: 12/31/2025

Corrective Action Plan: During Q4 2025, Shiloh’s general purchasing policy will be updated to consider the requirements included in 2 CFR 200.328 through 200.326. (Note: This update was originally to be implemented in Q4 2024 but was delayed due to unexpected turnover in the Business Department.)