Corrective Action Plans

The District is in the process of updating the Federal Procurement Procedures with the new thresholds that were issued in September. The District will get quotes for all items purchased with Federal funding in the future to avoid future findings. New Philadelphia City School District makes every effort to procure items based on the policies and procedures in place. We also follow the Uniform Guidance to the best of our ability.

The Town will revise procurement procedures to ensure that written contracts are executed prior to the commencement of work for material projects. Procedures will include emergency procurement protocols consistent with 2 CFR §200.320(c), requiring written justification and documentation when public exigency is used. Staff will be trained on federal procurement requirements, including contract execution and documentation standards.

Procurement – Assistance Listing No. 14.267 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: The Organization will update its procurement policy to include a formal pre‑approved vendor list and documentation requirements for all procurement methods. Management will standardize procurement files to ensure inclusion of required support, such as vendor selection rationale, cost or price analysis, and approval documentation. Procurement staff will receive training on updated policy requirements, and compliance will be periodically reviewed by management. Name(s) of the contact person(s) responsible for corrective action: Scott Russell Planned completion date for corrective action plan: 6/30/2026

Management concurs with the finding. Dir of Finance will take responsibility for ensuring adherence to follow all procurement policies and procedures. In addition, the VP of Finance will perform an Inservice to all key stakeholders within the facility under all procurement policies and procedures. The Dir of Finance is leading targeted training initiatives for finance staff and relevant personnel on the revised policy and procedures to ensure proper application. Quarterly we will review all purchases to ensure compliance with policies and procedures. These processes will be supervised by the VP of Finance/Director of Finance and were completed in February 2026.

The Town acknowledges that small purchase procedures were not followed in the transaction that occurred. Price reasonableness was not insured and bids were not obtained. The Mayor and Town Clerk shall improve procurement procedures and obtain a minimum of three bids on all projects that do not require public bidding or that are not on state contracts above the procedure threshold established by the Town. The Town will further update its written procurement policies and procedures to clearly define small purchase requirements, including quotation thresholds and documentation standards. Procurement staff will solicit and retain documentation of price or rate quotations from an adequate number of qualified sources for all small purchases. The staff will receive training under 2 CFR Part 200, including informal procurement methods and finally the Town will implement a supervisory review procurement file system to ensure compliance prior to payment, a checklist of sort to ensure proper document is secured.

Management's Response: The School District concurs with the recommendation. We recognize the importance of maintaining strong internal controls to ensure that all procurement activities are conducted in full compliance with Uniform Guidance (2 CFR Part 200) requirements. To address this recommendation, the District will enhance its existing procurement procedures by: 1. Developing and Formalizing Written Internal Controls. 2. Implementing Staff Training. 3. Strengthening Monitoring and Review Processes.

Audit Finding Reference: 2025-001 Planned Corrective Action: The Student Services and Food Service departments in Southwick-Tolland-Granville Regional School District will immediately ensure complete implementation of our internal control protocols regarding procurement. For any purchase that requires competitive procurement, we will conduct market research, obtain multiple quotes, or use the IFB/RFP process, if necessary. We will only engage in sole source procurement when we have determined that there is only one single provider of the good or service, and we will document that determination accordingly. We will enter into contracts with vendors when purchasing goods or services from them. We will use purchase orders to ensure that funds are encumbered and not over expended. Lastly, we will keep all procurement documentation on file, including quotes, bids, and sole source letters. Staff who engage in our purchasing process, including our Director of Student Services, our Director of School Nutrition, our Supervisor of Buildings and Grounds, and our Director of Technology will be retrained in our procurement protocols and will be expected to implement them immediately going forward. The Director of Finance and Operations will review all purchase requisitions to ensure that the appropriate steps have been taken. Planned Implementation Date of Corrective Action: April 17, 2026 Person Responsible for Corrective Action: Nicholas Bernier Director of Finance and Operations Southwick-Tolland-Granville Regional School District

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

The Municipality will strengthen internal control and procedures to use adequate procurement process for the acquisition of goods and services in open competition to ensure that the Municipality receives a significant number of quotations from suppliers. Also, the Municipality will review and strengthen the purchasing procedures, to ensure that at least three quotations are requested from the suppliers. Implementation Date: Partially corrected Responsible Person: Mrs. María Ortiz Martínez Finance Department Director

Federal Agency: U.S. Department of Housing and Urban Development U.S. Department of Health and Human Services Federal Program Name: Continuum of Care Program Center for Substance Abuse Treatment - Certified Community Behavioral Health Clinic Assistance Listing Number: 14.267 93.696 Direct Federal Award Program: PA0029L3T002316 - Tioga Arms PA0568L3T002308 - Shelton Court 22TI85374A – Certified Community Behavioral Health Clinic Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Condition: As part of our audit procedures over the Organization’s procurement policy and the small purchase requirements under 2 CFR 200.320(a)(2), we sampled a total of five vendors who incurred costs exceeding $10,000 for each of the two major programs. For three of the five vendors selected, management was unable to provide written documentation demonstrating that price or rate quotations were obtained from an adequate number of qualified sources (generally 2-3 quotes) for purchases above the micro-purchase threshold ($10,000) and below the Simplified Acquisition Threshold ($250,000). This documentation should have included the names of suppliers contacted, prices quoted, and the justification for vendor selection. Recommendation: We recommend management update its policies and procedures over procurement to ensure compliance with 2 CFR Part 200. This includes requiring and retaining documentation supporting the use of small purchase procedures, obtaining price or rate quotations from an adequate number of qualified sources, and monitoring vendor expenditures on an aggregate basis to ensure the appropriate procurement method is applied. Management should also provide training for staff responsible for procurement activities to promote consistent compliance with federal requirements. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges the deficiency related to procurement documentation and compliance. While the Organization has procurement practices in place, documentation supporting the solicitation of price or rate quotations from an adequate number of qualified sources was not consistently maintained for certain purchases during the audit period. In certain instances, vendor selection was influenced by the need to ensure continuity of care and avoid disruption to critical services provided to clients. As a result, management prioritized maintaining established vendor relationships to support uninterrupted service delivery; however, formal documentation supporting this rationale was not consistently retained in accordance with procurement requirements. To address this matter, management will update and formalize procurement policies and procedures to ensure full compliance with federal requirements. This will include clearly defined documentation standards for all purchases exceeding the micro-purchase threshold, including retention of vendor quotes, identification of suppliers contacted, and justification for vendor selection—including instances where continuity of care is a determining factor. In addition, training will be provided to all staff involved in procurement activities to reinforce compliance expectations and documentation requirements. Management expects these corrective actions to be implemented in the current fiscal year and will conduct periodic reviews to ensure adherence and ongoing compliance. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026

Views of Responsible Officials: Management acknowledges the comment. Subsequent to fiscal year-end, we implemented enhanced internal procedures to ensure procurement activities are properly conducted and documented for consultants. In instances where a sole-source procurement is utilized, we now ensure that the justification and supporting rationale are thoroughly documented.

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

Procurement Noncompliance Auditor Description of Condition and Effect. During our testing of four procurement transactions charged to the federal award, we noted that the College procured goods/services totaling $18,750 from a single vendor using a sole source justification. The College did not obtain the required quotes for the purchase. Our review of the documentation determined that the rationale provided for sole source procurement did not meet the criteria outlined in Uniform Guidance. As a result, the College did not follow required competitive procurement procedures. Because competitive procurement procedures were not used, the College may not have obtained the best price or ensured full and open competition. Auditor Recommendation. We recommend that the College strengthen internal controls to ensure personnel verify and document that sole source criteria under 2 CFR §200.320 are fully met before awarding a procurement without competition. Corrective Action. Staff will retain documentation to substantiate single-source procurement transactions prior to award or contract execution and will be reviewed by the Controller. Responsible Person. Jennifer Dodson, Controller Anticipated Completion Date. June 30, 2026

Finding Numbers: 2025‐002, 2024‐002 Program Name/Assistance Listing Titles: Indian School Equalization; Administrative Cost Grants for Indian Schools, Special Education Cluster (IDEA) Assistance Listing Numbers: 15.042; 15.046, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School’s internal controls over procurement of goods and services were not adequate. - A change in office staff just before the audit visit made finding documentation related to procurement difficult. Efforts to improve in this area have been made and will continue to be a focus of the administration. Procurement procedures are in place and are being followed, but record keeping remains a challenge. A new hire in this area with training emphasis is needed.

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