Corrective Action Plans

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

Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for Federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.

FINDING 2024-005 Finding Subject: Child Nutrition Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Formal procurement procedures have been established including micro-purchase and small purchase thresholds. Required price quotes are obtained and documented. Procurement history is maintained, including rationale and vendor selection. Vendor suspension and debarment checks are performed using SAM.gov or certifications. OPAA provides oversight of procurement processes and monitoring is ongoing. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance procurement control activities, and provide ongoing monitoring to ensure compliance with federal procurement standards, suspension and debarment requirements, and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

The Treasurer's Office will review all contracts and expenditures funded with Federal awards to ensure compliance with applicable procurement requirements under 2 CFR §200. Prior to entering into agreements with the Educational Service Center that will be paid from Federal funds, the District will either: • Conduct the appropriate competitive procurement process and maintain supporting documentation, or • Complete and retain the Ohio Department of Education and Workforce's Noncompetitive Proposal Request for Educational Service Center Services, when applicable.

Develop procurement policy for federal grants noting that bids on federal grants will be advertised for at least three weeks.

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: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Anticipated Completion Date: December 2026

Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2023-003) and current year renumbered recommendation (2024-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h); and development of a comprehensive Health Resources & Services Administration (HRSA) group of related policies and procedures. A. Financial Policies – May 2025. While the Organization initially prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024, by May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Simultaneous to the policy work described above, several processes to guide and align procurement practices, throughout the Organization, was initiated, including the use of MTPF, Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal, and to date implementation of the processes continue. C. HRSA Policies – July 2025. By July 2025, the Organization developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. In August 2025, the Board was provided policies developed within the Organization’s policy framework, including the above policies. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.

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

The district will create an SOP for procurement activities moving forward as well as making sure to train staff responsible for procurement to ensure compliance with Federal compliance.

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained.

Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for the projects selected. In conjunction with our fiscal year 2024 audit, please see the City’s corrective action plan below: To address the audit finding, management concurs with the finding that procurement documentation for CSLFRF‑funded projects was insufficient to demonstrate compliance with federal procurement standards, including the requirement for public notice under 2 CFR § 200.320(b). The absence of complete records limited the City’s ability to show that full and open competition was provided. The City will revise and strengthen its procurement policies to require formal solicitation and complete documentation for all applicable projects. A centralized system for retaining procurement records will be implemented to ensure that evidence of public notice, solicitation efforts, bid evaluations, and contract award decisions is consistently maintained. Staff involved in procurement will receive training on federal requirements, and a pre‑award compliance checklist will be introduced to verify that all required documentation is in place before contracts are executed. Management will work with all departments involved in procurement to reinforce expectations, implement improved procedures, and ensure that required documentation is consistently retained.

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

Finding 2024-001: Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Condition: During our testing of procurement for ALN 21.027, we noted that the City procured certain goods/services through the Commonwealth of Pennsylvania’s COSTARS cooperative purchasing program. For items selected for testing, totaling $184,512, the City did not conduct its own competitive procurement process. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. The City does not have implemented monitoring procedures over its use of COSTARS, including [e.g., periodic review of COSTARS procurement documentation, confirmation that COSTARS contracts were competitively awarded, and verification that applicable federal clauses are incorporated]. Documentation in the procurement files was not sufficient to clearly demonstrate how the underlying COSTARS procurement complied with the Uniform Guidance procurement standards for the specific federal award (e.g., basis for contractor selection, method of procurement relative to 2 CFR 200.320 thresholds, and required federal contract provisions). Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the value of the procurement transaction. Cooperative purchasing arrangements (such as state contracts or COSTARS) are not prohibited by the Uniform Guidance; however, the municipality must assume responsibility for the procurement and document how the cooperative contract satisfies the federal procurement requirements applicable to the award. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. The City has chosen to leverage the COSTARS cooperative purchasing program to improve efficiency and obtain favorable pricing. While the City has implemented monitoring over COSTARS (for example, reviewing selected COSTARS contract information and maintaining communication with the state regarding procurement practices), those procedures have not been formalized in the written procurement policy, and the related documentation is not consistently retained in the individual grant procurement files. As a result, the audit file did not contain clear, consistent evidence that the COSTARS contracts used for the tested transactions met all applicable Uniform Guidance procurement requirements. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. In addition, without documentation demonstrating clear, consistent evidence that COSTARS contracts used for purchases met all applicable Uniform Guidance procurement requirements, there is an increased risk of noncompliance which could result in unallowable costs being charged to the Federal awards. Repeat finding: Yes, finding 2023-002 Questioned costs known and likely: $184,512 known and $124,662 likely. Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows all Uniform Guidance procurement standards, especially regarding cooperating purchasing programs. View of Responsible Officials and Corrective Action Plan: Management agrees with this finding. Although procedures were previously established to ensure compliance with Uniform Guidance procurement standards, the finding recurred due to inconsistent implementation and insufficient monitoring of those procedures, particularly related to the use and documentation of cooperative purchasing programs.