Corrective Action Plans

FINDING 2025-001 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Samantha Berrier Contact Phone Number and Email Address: 219-962-2909, sberrier@rfcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The offices of the Northwest Indiana Special Education Cooperative (NISEC), on behalf of River Forest Community School Corporation, its member school, has implemented a corrective action plan to ensure that the proper methodology for procurement is followed. Additionally, a system of internal controls has been established to ensure that vendors are procured using the required methods. The Northwest Indiana Special Education Cooperative created a corrective action plan to develop procedures to obtain bids when any vendor will exceed the simplified acquisition threshold. As part of this corrective action plan they have included procedures to follow if a noncompetitive procurement would be applicable. These procedures include documenting the rationale for using this alternative method and requesting approval from the Board of School Trustees when doing so. Anticipated Completion Date: October 9th, 2024

FINDING 2025-001: PROCUREMENT (50000) Federal Agency: U.S. Department of Education Passthrough Entity: California Department of Education Program Names: Individuals with Disabilities Education Act (IDEA) (AL No. 84.027, 84.173) Response to finding: During the 2025-26 fiscal year, the District implemented changes to reclassify certain contracts from federal funding sources to state funding. The District utilized the SELPA Master Contract for applicable vendors to ensure proper contracting and compliance. Federal funds will continue to be used to support Instructional Aides (IAs). These actions were taken to improve alignment with funding requirements and strengthen fiscal compliance. The Assistant Superintendent of Educational Services is responsible for monitoring and implementing federal procurement procedures to ensure compliance. This procedure was implemented beginning the 2025–26 School Year.

CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This policy, which includes a Conflict of Interest section, was updated to reflect a decrease of the micro-purchase threshold from $50,000 to $10,000, clarifies that the SAM.gov check for suspension and debarment will occur prior to contract execution with the contractor, and the SAM.gov check will be documented with the date it was conducted. The updated CIF Procurement Policies & Procedures will be approved by the Board of Directors.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Missy Schultheis Contact Phone Number and Email Address: 812-354-8478 mschultheis@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review and update the existing procurement policy to ensure it clearly outlines the procedures for different purchasing methods including the specific thresholds. We will establish a procedure requiring the retention of all documentation supporting procurement decisions. We will develop a process to verify that vendors/contractors are not suspended or debarred by any federal or state agency prior to entering into a "covered transaction" or contract. Anticipated Completion Date: This be implemented in the 2025-2026 school year and will continue for future years.

Corrective Action Plan: The Loysville Village Municipal Authority disagrees with this finding. The Authority is bound by the procurement procedures contained in the Municipal Authorities Act (Pennsylvania law) and has signed agreements with USDA governing its procurement procedures. These documents are in writing and any additional policy for this purpose would either by conflicting or superfluous. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Secretary, Barry Enck, Treasurer

The District will include checking SAM.gov for suspension and debarment. A spreadsheet will be created tracking all vendors that federal grant dollars are used for. A digital capture of the proof will be stored in a folder for future reference.

Corrective Action Plan Contact Person(s): Janet Carbary, Deana Gilpin Management agrees with this finding and recognizes the need to strengthen internal controls over purchasing processes to ensure compliance with Uniform Guidance requirements (§200.317–§200.326; §200.213). To address the deficiency, the Organization will implement the following actions: 1. Update Purchasing Policies and Procedures o Purchasing policies will be revised to clearly incorporate Uniform Guidance requirements, including competitive bidding thresholds, procurement method selection, and documentation standards. o Policies will explicitly require verification of suspension and debarment status for all vendors receiving federal funds. 2. Implement Mandatory Suspension and Debarment Verification o Staff will be required to document verification through SAM.gov or other approved sources before awarding or renewing contracts funded by federal awards. o A verification will be maintained and reviewed by Finance leadership. 3. Enhance Procurement Documentation Controls o Leadership will ensure all federal purchases meet the requirement below before purchase approval. • Competitive purchasing requirements are met • Cost/price analyses are documented when required • Suspension/debarment verifications are completed and retained 4. Training for Finance Staff o Staff involved in purchasing, contract approval, and grant management will receive training on Uniform Guidance procurement rules and suspension/debarment requirements. 5. Periodic Internal Monitoring o Revenue accountant will monitor expenses related to federal programs monthly to ensure compliance. o Senior management will be notified if corrective steps are needed. Anticipated Completion Date: December 31, 2025 Responsible Officials: • Chief Financial Officer (CFO) • Accounting Manager • Director of Financial Planning

Procurement Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplified acquisition method of procurement. 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: Management acknowledges that even though grant objectives were met, procurement procedures must be followed regardless of timeline constraints. Management has implemented enhanced controls to ensure compliance with internal procurement policies, including: (1) mandatory documentation for simplified acquisitions requiring evidence of price reasonableness; (2) staff meetings on procurement requirements; and (3) supervisory review of procurement files prior to grant invoice submission. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025

The District will develop and implement a formal procurement checklist. This checklist will be completed by the Business Manager for all purchases expected to exceed the micro-puchase threshold. The procedure will require the checklist to be completed and attached to the purchase order before the purchase is finalized, ensuring and documenting that the required price of rate quotations have been obtained in accordance with 2 CFR section 200.320.

The District Cafeteria Manager, Melanie Pardini, corrected this procedure for fiscal year 2025-26 and has the process in place going forward for each fiscal year.

Corrective Action Plan for Audit Finding 2025-003: Procurement Procedures (Significant Deficiency and Noncompliance - IDEA Special Education Federal Program) Finding Summary: Auditors identified two instances in which procurement transactions did not comply with the District's procurement policy or federal Uniform Guidance requirements. Specifically, bids were not solicited as required, and suspension and debarment checks were not performed or documented for the vendors prior to contract award. Root Cause: The exceptions occured due to a gap in the District's internal control structure. These procedures were not being consistently performed, and prior management was unaware the requirements under federal Uniform Guidance were not being followed. Corrective Action: The District will establish and implement policies and procedures to ensure all federally funded procurements comply with Uniform Guidance requirements. This includes: 1. Soliciting bids or proposals in accordance with applicable competitive procurement thresholds. 2. Performing and documenting suspension and debarment verifications for all vendors, including tracking results appropriately. 3. Providing training to staff responsible for federal procurement to ensure ongoing compliance and understanding of federal requirements. These actions are intended to ensure that contracts are awarded fairly, to responsible parties, and in full compliance with federal regulations. Documentation of all procurement steps will be maintained to demonstrate compliance during future audits. Responsible Parties: Fiona Barry, Assistant CFO, and Matthew Gonzales, CFO, are responsible for overseeing implementation, ensuring proper documentation, and providing staff training. Timeline: The corrective actions are scheduled for implementation by March 2026 and will continue as part of the District's ongoing procurement compliance process.

There is no disagreement with the finding. Management will review policies in alignment with minimum Uniform Grant Guidance procurement thresholds and District documentation of internal controls related to policy.

OBI will update current purchasing and procurement policy to specifically address the acquisition of property or services using federal grant funds to ensure adherence to Federal procurement standards in 2 CFR Part 200 sections 200.317-200.327. Our policy will outline requirements regarding vendor selection and vendor qualification. It will address the simplified acquisition threshold, micro purchases threshold, and the formal procurement methods that must be adhered to when the value exceeds those thresholds. The policy will include when sealed bids, proposals/requests for proposals are required and when sole source procurement is appropriate and allowable. Whenever sole source procurement is used, the rationale will be documented and approved. Our policy will include language requiring that all vendors and contractors paid using federal funds be checked for federal suspension & debarment using Sam.gov. Vendors found on the exclusion list will not be paid using federal funds. The policy outlines requirements for written approvals and documentation of all procurements. Additionally, OBI has implemented procedures to ensure that at the point of receiving the Notice of Award, any federal money or grant awarded to OBI will be immediately communicated to the CFO, Controller, and the Senior Accountant. Person(s) Responsible: Senior Accountant with review and approvals from Controller and CFO Estimated Completion Date: January 31, 2026

CONTACT PERSON: Matt Pettit, Chief Financial Officer, matthew.pettit@cherokee1.org CORRECTIVE ACTION: The District will ensure that it does not use local exemptions for any federal programs. PROPOSED COMPLETION DATE: Prior to June 30, 2026

CONTACT PERSON: Matt Owens, Chief Financial Officer, mattowens@pickens.k12.sc.us CORRECTIVE ACTION: The District has implemented procedures to ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. PROPOSED COMPLETION DATE: Prior to June 30, 2026

Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026

Finding: 2025-001: Procurement Noncompliance - Child Nutrition Cluster. Contact Person: Lisa Hammerly, Director of Business Services. Recommendation: The District should continue to implement and monitor updated procurement procedures, including use of centralized tracking, pre-approval of purchases, and adherence to formal solicitation processes. Corrective Action: The District agrees with the finding. Corrective action was initiated in April 2025, including adoption of revised procurement procedures, implementation of monitored tracking, and initiation of a formal bid process for recurring food purchases. Proposed Completion Date: Policy revision completed March 2025, staff training completed April 2025, monthly monitoring effective beginning May 2025.

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micropurchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Small Purchase Procurement: We have enhanced document retention procedures around small purchase procurement including staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure a minimum of 3 bids/quotes are obtained on any grant-funded purchases or services greater than $10k. We will be utilizing NetSuite's Document Library to manage document retention for grant-related bids and quotes. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

Management's Response: AMHE has established policies and procedures for the creation, approval, submission and retention of all required reports. On September 27, 2018 AMHE updated and adopted the Financial Management Policy and Procedures. Page 6, Section 8, Financial Reports states: "The TDHE must be able to produce accurate, current, and complete disclosure of the financial results of each of the financially assisted activities made in accordance with the financial reporting requirements of the grant or sub-grant. The TONE shall use the financial reports as tools to manage, control, ensure compliance, monitor, and inform the TDHE on its financial activities. Reports to Grant Agencies: The TDHE shall complete and submit all reports to Federal, State, and local grant agencies in accordance with, and in the format and timelines required by the agency. The Executive Director will oversee all administrative and financial reports, including the HUD Standard Form 425, the INP and the APR, before the due dates designated by HUD, as such forms and deadlines may change from time to time." AMHE will do better in adhering to our Financial Management Policy and Procedures moving forward and getting the reports submitted in a timely manner. Estimated Completion Date: Immediately AMHE will adhere to the practice of the Financial Reporting of the Financial Management Policy and Procedures. This will be addressed with AMHE staff prior to 6/30/26. Responsible Party: Comptroller and Interim Director.

The Village will establish formal UG policies and procedures.

Views of Responsible Officials and Planned Corrective Actions: ATS has drafted an organization-wide procurement policy to ensure it includes all the Uniform guidance procurement elements. The draft will be reviewed by senior management for comment prior to formal issuance.

Management acknowledges that procurement documentation was not consistently maintained during the audit period. Since that time, improvements have been made; however, additional work is ongoing to fully standardize documentation practices across the Organization. Staffing stability since September 2024 has improved consistency and accountability. A Vice President of Programs has been hired to strengthen compliance oversight, and a Compliance & Risk Management Committee will be established in FY2026 to support organization-wide monitoring. The Organization is also implementing targeted training on 2 CFR Part 200 for fiscal, program, and contracts staff to reinforce procurement requirements. In addition, enhancements to procurement procedures and documentation standards are underway. The implementation of Blackbaud Financial Edge in FY2027 will further strengthen internal controls through improved workflows, tracking, and documentation retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken - Reinforced procurement documentation expectations with program and administrative staff - Increased supervisory review of procurement transactions - Hired a Vice President of Programs to strengthen compliance oversight - Established plans to launch a Compliance & Risk Management Committee in FY2026 - Initiated cross-functional training on 2 CFR Part 200 for fiscal, program, and contracts staff - Began enhancing procurement policies, procedures, and documentation standards - Initiated implementation of Blackbaud Financial Edge to support procurement tracking and internal controls.

2024-003 Material weakness in internal control over compliance Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance requirement: Procurement, suspension and debarment Recommendation: We recommend management enhance procedures and controls to ensure documentation is maintained to support all suspension and debarment verifications related to expenditures from federal award programs. Such documentation should be consolidated and maintained in a secure, accessible location. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2026 the Borough responded with an SOP to outline the procedures implemented in response to the material weakness finding for internal controls. The SOP outlines, the process for verifying suspension and debarment verification through SAM.gov or another third party resource before federal award payments are made. All vendors are required to be verified prior to payment and annually, with record keeping maintained in a secure location by the finance team. Name(s) of the contact person(s) responsible for corrective action: Layla Richard-Rau, Director of Finance Planned completion date for corrective action plan: Implementation to take place on or before April 27, 2026.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury 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