Corrective Action Plans

2024-001 – Internal Controls over Compliance and Compliance with Procurement Standards Individual Responsible for Corrective Action Plan: Meghan Davies, Chief Operating Officer Anticipated Completion Date: Effective immediately Corrective Action Plan: WWH’s Chief Operating Officer will be the single point person responsible for ensuring all federally funded procurements are managed properly and that all documentation is maintained. In addition, an extra step will be taken to duplicate the filing system for all federally funded procurements into the grants management files themselves.

Re: Management’s Response & Corrective Action Plan to Procurement Policy & Procurement Action Documentation (2024-004) The Wilmington Land Bank adopted a written Procurement Policy on September 11, 2024. At one property, however, the policy was not fully followed. The Land Bank initially considered the work a continuation of an existing project, but it was later determined that it should have been bid separately under the Procurement Policy. To strengthen compliance with the Procurement Policy going forward, the Land Bank will hold weekly internal staff meetings and weekly meetings with the City of Wilmington. These meetings will include a review of project updates and related procurement actions. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

Condition: Controls in place were not adequate to ensure the policy included a well-defined Simplified Acquisition Threshold and related procurement method. Additionally, controls were not adequate to ensure price or rate quotations were obtained from an adequate number of qualified sources for contracts above the Simplified Acquisition Threshold. Planned Corrective Action: Management understands the importance of adhering to procurement thresholds and methods. Procurement policies and Grant policies will be updated to include federal thresholds and methods to reflect federal Uniform Guidance. Additionally, the procurement procedures will be amended to include additional review and sign-off from Grant and Purchasing leadership prior to purchases being made with federal funds to ensure price and rate quotations were obtained for contracts above the Simplified Acquisition Threshold. Contact person responsible for corrective action: Stephanie Cihon and Andy Vollmar Anticipated Completion Date: October 31, 2025

Adopting procurement policy that complies with UG procurement standards and distributed it to all staff with purchasing authority. The ED and Treasurer are currently developing a checklist that will be included as part of initiating contracts or purchases over the procurement threshold and that it is saved along with other grant documents. The bookkeeper will check the SAM data base for disbarment notices prior to queuing bills for amounts greater than $5,000 for payment

Corrective Action Plan for Finding 2024-01 Type of Finding: Internal Control and Compliance - Compliance and Material Weakness Deficiency over Procurement and Suspension and Debarment Federal Program: U.S. Department of Treasury, American Rescue Plan Act (ARPA) Federal Assistance Listing No.: 21.027 Condition: During the single audit, there was a finding of no documentation to support a competitive bidding or procurement process for certain vendor contracts, as required by federal procurement standards. Corrective Actions 1. Revise Internal Procurement Policy A. Action: The organization will revise its existing procurement policy to adhere with federal requirements for competitive bidding, including thresholds for different procurement methods (e.g., micro-purchases, small purchases, sealed bids, competitive proposals). The revised policy will clearly define the documentation required for each step of the procurement process. B. Responsible Party: Kimberly Royster (CFO) C. Anticipated Completion Date: October 15, 20252. Provide Mandatory Staff Training A. Action: The organization will train all employees, including those in finance, program management, and administration, on the new procurement policy and process. The training will emphasize the importance of compliance with federal regulations and the specific documentation requirements. B. Responsible Party: Wayne Lawson (HR) and Laura Connelly C. Anticipated Completion Date: November 12, 2025 3. Implement the Revised Procurement and Documentation System A. Action: The organization will implement the new procurement process for all procurement activities. This process will require documentation of all stages of the procurement process, from the initial request to the final contract award. This will ensure that a complete audit trail is maintained for every purchase. B. Responsible Party: Laura Connelly C. Anticipated Completion Date: November 12, 2025 4. Conduct Post-Implementation Monitoring A. Action: The organization will enlist the services of the external audit team to review the updated procedures. This will serve as a check to ensure the new policy meets federal requirements. B. Responsible Party: Current Auditor C. Anticipated Completion Date: December 31, 2025

2024-004 Coronavirus State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Recommendation: We recommend the County follow procurement policy that is in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will follow procurement policy that is in accordance with Uniform Guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager. Planned completion date for corrective action plan: December 31, 2025.

Recommendation: We recommend the Foundation strengthen its policies and procedures to ensure procurement is adequately documented for the goods and services purchased in accordance with Uniform Guidance and other federal guidelines, including simplified acquisition procedures for purchases above the micro-purchase threshold ($10,000). Grantee Response and Corrective Action Plan 2024-001: In response to the audit finding under 2 CFR Section 200.320 regarding the necessity to have and use documented procurement procedures for acquisition of goods and services under a federal award or a sub‐award, it is acknowledged that the Foundation did not previously have a formal policy specifically addressing procurement. Recognizing the importance of formalizing these practices into policy, we are committed to developing and implementing a comprehensive policy that explicitly addresses procurement. In line with our recent enhancements in internal controls, including the engagement of a Finance Manager in 2024, this policy will reinforce our ongoing efforts to uphold the highest standards of compliance and accountability in all our operations. Responsible Parties: Allie Kelly, Executive Director Anticipated Correction Date: December 31, 2025

The audit identified gaps in our procurement policies and procedures. In response, updated procurement policies have already been drafted. These policies align with federal requirements, strengthen internal controls, and establish clearer guidelines for competitive bidding, documentation and approval processes. The draft policies are currently under review by the Executive Director and will be finalized and implemented promptly.

Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026

Reporting - Reportable Findings and Questioned Costs for Federal Awards Contact Person Marc Taylor, CFO E-Mail: Marc@chiefseattleclub.org Corrective Action Planned This finding occurred because of a lack of both procurement knowledge and staff oversight over a contractor handling the procurement for Eagle Village. Thanks to this finding, our real estate team has gained a better understanding of federal procurement requirements. Our auditor provided us with a procurement checklist, which we began using and will ensure that we comply with our procurement policy and better document future procurements. Anticipated Completion Date September 30, 2025

As stated in the Management Letter issued by SAX regarding the Organizations procurement policy, 2024 was the first year the Organization received federal funding and therefore was not aware of the specific language required by the Uniform Guidance (2 CFR §200.317-.327) needed in the procurement policy. The Organization has worked with SAX to add policies to procurement policies to ensure that any future procurements required by federal funding received will include procedures required under the Uniform Guidance (2 CFR §200.317-.327).

FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025

Finding 2024-002 – 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. Additionally, 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. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead 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 October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025

Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom pliant with federal procurement standards. Since the policy adoption, all new procurements have followed the updated procedures. The organization also did not keep records of debarment search results. • What's been done: All procurement following the adoption of the procurement policy has been done in alignment with the policy. We also introduced procurement "kickoff meetings" for new grants to review each budget line, determine the correct procurement method, and plan documentation for the procurement process. This has been piloted with our most recent grant. All vendors now have debarment searches in their QuickBooks vendor information tab. • Next steps: Apply this process to all new grants to ensure compliance from the outset. • Responsible party: Finance manager and Executive Director of Michigan Center for Adult College Success with oversight by President

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