Corrective Action Plans

2025-006: WAGE RATE COMPLIANCE The School District will strengthen controls over federally funded construction projects to ensure applicable wage rate requirements are met prior to any work being completed by making sure all grant agreements, regulations and guidelines are followed before bid issuance and making sure wage-rate requirements are in the bid and contract documents. The people responsible for this will be the Board, Superintendent, and District Clerk.

The District is in the process of reviewing its procurement practices. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

The District is in the process of reviewing its procurement practices. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

Corrective Action Plan Finding 2025-002 Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Tim Stay, CEO Timeline: All future contract solicitations will follow the required procurement standards.

Finding Summary: NNCH did not properly procure three contracts in accordance with applicable procurement requirements and the Organization's procurement policy. Additionally, procedures were not sufficient to ensure that contracts contained all provisions required under Uniform Guidance. Responsible Individuals: Matthew Fleming, Executive Director; Jocelyn Kendall-Perez, Deputy Director & CFO Corrective Action Plan: Management acknowledges the finding and has reviewed the circumstances surrounding the contracts identified with the independent auditors. Two of the three contracts identified involved specialized professional services, including a development consultant whose engagement originated prior to NNCH's receipt of the applicable federal funding and a procurement management consultant. Although management considered the specialized nature and circumstances of these engagements when making the contracting decisions, NNCH recognizes that the procurement documentation maintained did not sufficiently demonstrate compliance with the applicable federal procurement requirements. As part of management's review of this finding with the independent auditors, NNCH discussed adopting a more conservative procurement approach for future contracting. Going forward, NNCH intends to evaluate and document procurements with the expectation that federal funding requirements may ultimately apply, even when federal funding is not anticipated at the time the contract is initiated. This approach is intended to provide greater flexibility if a funding source changes during the term of an engagement and to reduce the risk of an existing contract later being determined ineligible for federal reimbursement due to procurement requirements. NNCH will update its procurement procedures and develop a standardized procurement checklist addressing applicable procurement thresholds, required competition, documentation of permissible noncompetitive procurement when applicable, required approvals, suspension and debarment verification, and applicable federal contract provisions. Procurement documentation will be maintained with the applicable contract or project records. NNCH will also review applicable contracts prior to execution to verify that required procurement documentation and contract provisions have been addressed. Staff involved in contracting and procurement will receive guidance regarding the revised procedures and documentation requirements. Anticipated Completion Date: December 31, 2026

The Finance Officer, Cory Kappenman, is the contact person at this entity responsible for the corrective action plan for this finding. The City will establish controls to follow all applicable procurement requirements under the Uniform Guidance and applicable CFR sections.

Finding 2025-006 United States Environmental Protection Agency Federal Financial Assistance Listing #66.458/66.468 Capitalization Grants for Clean Water State Revolving Funds Material Weakness in Internal Control over Compliance Finding Summary: In our testing of procurement, suspension, and debarment it was identified that the City’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Sarah Hellekson, City Administrator Corrective Action Plan: Management will establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2026

Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors' concerns regarding the retention and availability of historical procurement documentation. However, SWK notes that this finding relates primarily to documentation retention and retrieval rather than a failure to perform procurement activities or suspension and debarment verification. The primary issue resulted from the termination of the Unaccompanied Alien Children (UAC) Program during Fiscal Year 2025, which led to significant organizational downsizing, including the elimination of the Procurement Department. Historical procurement, solicitation, and bid documentation had been maintained within a procurement software platform administered by that department. Following program closure and the departure of procurement personnel, the software platform was decommissioned, resulting in certain historical procurement records no longer being readily accessible during the audit. SWK did, however, provide evidence that vendors selected for procurement actions were screened for suspension and debarment in accordance with federal requirements. Additionally, two of the six contracts exceeding the simplified acquisition threshold represented renewals of previously procured contracts; however, complete historical bid files could not be retrieved for audit review. SWK further notes that as of the date of this corrective action plan: • The UAC Program has been terminated. • SWK no longer maintains a dedicated Procurement Department. • SWK has no active federal procurement contracts over $250,000 requiring formal solicitation procedures. • No questioned costs were identified by the auditors. • The auditors concluded that services and goods purchased under the reviewed contracts were allowable and supported program operations. Corrective Actions Although the circumstances surrounding this finding relate to historical records associated with a discontinued program, SWK has implemented the following actions to strengthen document retention and procurement oversight for any future federally funded procurements: 1. Centralized Procurement Record Retention SWK has established a requirement that all procurement-related documentation, including solicitations, bid responses, evaluations, vendor selection justifications, contract approvals, and suspension/debarment verifications, be maintained in a centralized electronic repository controlled by Finance and Administration, rather than an individual department or software administrator. 2. Procurement Documentation Checklist SWK will continue to utilize a standardized procurement checklist for any future procurement transactions subject to federal procurement requirements. The checklist will ensure required documentation is retained and readily accessible for monitoring or audit purposes. 3. Enhanced Document Archiving Procedures Prior to the discontinuation of any program, department, or software platform, SWK will perform a records-retention review to ensure all procurement and contract documentation subject to federal record retention requirements is archived and preserved. 4. Management Oversight The Chief Administrative Officer will be responsible for periodic reviews of procurement files to verify that required documentation is complete and retained in accordance with federal and organizational requirements. 5. Future Procurements SWK will review and update its documented procurement procedures to conform to applicable federal statutes, the procurement requirements identified in 2 CFR Part 200, and the new federal procurement thresholds as of October 1, 2025. Further, SWK will institute a centralized purchasing function under Finance and Administration to facilitate the review of procurements to ensure compliance with both 2 CFR Part 200 and the terms and conditions of awards. This function will ensure the enforcement of the procedures mentioned above by: - Conducting vetted vendor onboarding and ongoing management via periodic reviews to verify that non-federal entities, contracts, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federal programs - Obtaining appropriate documentation of multiple vendor quotes and/or sole source justification for small purchases greater than the micro-purchase threshold, but below the simplified acquisition threshold - Managing, following, and documenting the simplified acquisition procedures for purchases greater than or equal to the simplified acquisition threshold Expected Completion Date: In process and to be completed by December 31, 2026 Ongoing monitoring and compliance reviews will continue for any future procurement activities. Status Corrective action substantially implemented. Upon review of current FY2026 purchases and due to the closure of the UAC Program, the risk associated with this finding has been significantly reduced. The corrective actions above are designed to ensure appropriate documentation retention and compliance should future federally funded procurement activities occur. Responsible Officials: Chief Administrative Officer, Marisol Cervera

Finding 2025-001 - COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Norfolk County Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: During our testing as it related to compliance with procurement we noted that an expense for engineering services for the Well #10 Permitting Project services charged to the major program would have required a formal bidding process as the project exceeded the simplified acquisition threshold of $250,000. Context: The Town had a ARPA project 1123 for well#l0 permitting project that they relied on a request for qualifications from 2011 for engineering services related to Town wide drinking water. The Well#l0 project was submitted on 12/20/22 for approval by Norfolk County. It is the auditor's professional judgment that separate procurement procedures should have been performed as the RFQ was approximately 11 years old and this was a new project. Although services are exempt under State procurement requirement, Federal Procurement rules would have required procurement procedures. Under Federal Procurement requirements expenses of $250,000 or more require a formal bid process. As the project costs and estimates at the time of the project exceeded $250,000, the Town should have performed formal bid procedures for this service. Questioned Costs: Based on vendor expenses charged to the grant in FY 2025 the total questioned costs were $54,060.65. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is a risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Itle11tijicatio11 as a Repeat Finding: 2024-002 Recommendation: Going forward, the Town of Bellingham should consider a separate bidding process for expenses related to federal grant awards. Responsible for Corrective Plan: CFO Estimated Completion Date: December 2026 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

Finding No. 2025-002: Procurement- Compliance Finding and Significant Deficiency in Internal Control over Compliance EPIC acknowledges that documentation confirming vendor suspension or debarment was not present in various vendor files for FY25. Corrective Action Plan: EPIC has updated its vendor onboarding process to include confirmation of all new vendors prior to being awarded contracts. In addition, all current vendors will be confirmed eligible to receive federal funds during the RFP process for each subsequent project award. Contact Person Responsible for Corrective Action: Thomas Sperti, Chief Financial Officer

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2025-003 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants – Assistance Listing No. 14.251 Recommendation: We recommend the Organization strengthen controls to ensure procurement documentation is consistently obtained, retained, and reviewed for compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has strengthened procurement procedures to ensure required documentation is consistently obtained, reviewed, and retained to support compliance with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Jeff Fournier, Finance Director Planned completion date for corrective action plan: June 30, 2026

Views of Responsible Officials and Planned Corrective Action: Management confirms that the procurement activities themselves were completed only after the appropriate review and approval processes had occurred; however, sufficient supporting documentation evidencing those procedures could not be located during the audit process. This condition occurred during a period of significant staffing transition and turnover, which contributed to inconsistencies in documentation retention and adherence to established federal procurement documentation requirements. Management recognizes that internal controls and compliance procedures must remain effective regardless of personnel changes and accepts responsibility for strengthening these controls to ensure consistent compliance. Upon identification of this issue, management conducted an assessment of the underlying procurement and documentation processes and determined that enhancements were necessary to improve accountability, standardize documentation practices, strengthen supervisory review, and reinforce staff training related to federal procurement requirements. Management emphasizes that the deficiency related to the retention and completeness of procurement documentation, rather than to the execution of the procurement process itself. Management believes the evaluation, selection, and approval activities were conducted in accordance with applicable federal procurement guidelines and standards. Management is currently reviewing procurement policies and procedures to ensure alignment with federal requirements related to quotations, vendor evaluation and selection, approval protocols, and document retention. Additional corrective actions include reinforcing documentation standards, clarifying approval responsibilities, and implementing enhanced monitoring procedures to help prevent recurrence.

Program: HOME Investment Partnerships Program Federal Financial Assistance Listing Number: 14.239 Federal Grantor: U.S. Department of Housing and Urban Development Award Number and Year: M16-MC060227; M17-MC060227; M20-MC060227; M21-MC060227; M23- MC060227; M24-MC060227 Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The City Engineering Department is the lead for all city capital projects and monitors prevailing wage requirements. The Housing Division is responsible for compliance with HUD specific requirements. This shared responsibility requires a high level of coordination and information sharing. The Housing Division does have draft of HOME Policies &Procedures which were prepared by a consulting firm contracted for the Five-year Consolidated Plan. These policies and procedures include Davis-Bacon and other related federal prevailing wage laws. Name of Responsible Person: Director of Development Services – currently vacant City Engineer - Daryl Jordan Housing Program Supervisor - Kimberly Nutt Projected Implementation Date: The consultant assisting the City has prepared a Draft of Policies and Procedures which are currently being reviewed. We anticipate final approval and implementation by end of January 2027.

The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide training to management staff on the procurement policies. Responsible Individual: Chief Financial Officer – Scott Korba Estimated Completion Date: October 2026-December 2026

We agree with the auditor's comments. A previously established procurement process titled School Fund Handbook was located, updated to reflect current purchasing process and policy per the Essex County Public Schools Policy Manual Section D, Fiscal Management on March 9, 2026. The Fund Handbook was distributed to administrative staff and a review and update recommended to incorporate all applicable requirements prescribed by 2 CFR §§ 200.318 through 200.326, including Federal procurement methods, competition requirements, documentation standards, and suspension and debarment requirements.

Recommendation: We recommend that the Town continue to strengthen its formal procurement policies with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While to finance department has a procedure in place to review the Excluded Parties List system to ensure that the vendor is not debarred or suspended and to document such confirmation, we will further strengthen our procurement policies as follows: As part of the bid and vendor review, the Town Engineer will print off the Excluded Parties List at that time, initial and date it, and keep it with all bid documents. This will ensure that the list has been checked prior to any contract being executed. The finance office will continue their review when the vendor is set up in the financial management system. Name(s) of the contact person(s) responsible for corrective action: Cherie Trahan Planned completion date for corrective action plan: 06/30/2026

Finding 2025-002 Procurement and Suspension and Debarment (Compliance) – 2020 Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In addition, the City did not retain adequate documentation for verification that vendors were not suspended or debarred parties. Corrective Action Plan Although the City was performing the review, the report from the SAM.gov website being maintained by the City to document said review did not provide evidence that there were no active exclusion records. Under the direction of the Finance Director working with the Senior Buyer / Analyst, this Procurement procedure and policy have been updated and distributed to the appropriate individuals. Adherence to this policy and procedure will be monitored by the Finance Director and the Internal Auditor.

Lynsey Darragh - Administrative Services Director, Lucas Mayo – Grant Administrator and Tony Pumphrey – Finance Director will develop procedures to ensure that all program reports have documented reviews; are submitted timely and that are reconciled to the accounting records before submission. Anticipated completion date is July 31, 2026.

Condition: We noted that the applicable wage determination information was not included in the funding agreement and related contract documentation for the project selected for testing. The City relied on Alabama Department of Transportation (ALDOT) to ensure all federally required provisions were included in the bid specifications and contracts. Although certified payrolls were submitted and the contractor complied with prevailing wage requirements, the required documentation was not formally included in the agreement package. Criteria: Federal regulations require that contracts and subcontracts for construction projects in excess of $2,000 financed with federal assistance funds include the applicable prevailing wage provisions and wage determinations under the Wage Rate Requirements (Davis-Bacon Act). In addition, contractors and subcontractors are required to submit weekly certified payrolls for each week work is performed. These requirements are established by 40 USC 3141-3147; 29 CFR Part 5; and 2 CFR section 200.326. Cause: The City relied on ALDOT's review and approval process for inclusion of required federal labor standard provisions and did not perform an independent verification that all Wage Rate Requirement provisions and wage determinations were included in the executed agreements.Effect: Failure to include all required Wage Rate Requirement provisions and documentation in construction agreements could result in noncompliance with federal requirements and increases the risk that contractors may not be properly informed of applicable prevailing wage requirements. Recommendation: We recommend the City implement procedures to independently verify that all federally required contract provisions, including applicable wage determinations and Davis-Bacon provisions, are included in bid specifications, contracts, and funding agreements prior to execution, even when projects are administered in coordination with third parties such as ALDOT. View of Responsible Officials and Planned Corrective Action: Management stated the project was administered through ALDOT and the City historically relied on ALDOT to ensure all required federal provisions were included in project documentation. Management noted that the funding agreement for this project did not include the wage determination information, although ALDOT later confirmed the requirements were applicable and certified payrolls were submitted. Management further indicated the contractor regularly performs ALDOT work and complied with the requirements. The City has updated its procedures to independently verify inclusion of all required federal compliance provisions going forward

CFDA 10.558 — Child and Adult Care Food Program Finding Type: Noncompliance / Significant Deficiency Corrective Action Plan The YMCA acknowledges the procurement finding related to the lack of formal agreements aiid procurement documentation for certain food vendors. Management has implemented the following corrective actions: 1. Develop and implement a formal procurement policy consistent with federal procurement requirements under 2 CFR 200.3 18-200.326. 2. Require written agreements or contracts for all vendors where annual purchases are reasonably expected to exceed the federal small purchase threshold. 3. Maintain procurement documentation, including vendor quotes, contracts, and bid documentation, in a centralized electronic file. 4. Provide annual training to staff responsible for purchasing and program oversight on federal procurement standards and documentation requirements. Responsible Party Gina Franklin and Karrie Stanford Expected Completion Date September 30, 2026

Finding 2025-058 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs, ALN 20.106 Management Views MDOT agrees that it did not ensure weekly certified payrolls were obtained from contractors. Planned Corrective Action MDOT will provide training and guidance to pertinent staff to help ensure contract compliance and that weekly certified payrolls are obtained from contractors. In addition, MDOT will review existing procedures to assess whether updates are needed. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Bryan Budds, MDOT

U.S. Department of Justice U.S. Department of Health and Human Services AUDIT FINDINGS: Finding Reference Number: 2025-001 Description of Finding: Family Centered Services of CT, Inc. had not updated its procurement policy to conform to requirements in accordance with the Uniform Guidance. The policy in effect during the first part of fiscal 2025 did not specify a micro-purchase or small purchase threshold above which written quotes would be required, although this was addressed in January 2025. A formal written policy for ensuring vendors are not suspended or debarred was not included in the old policy and, although the new policy does include such language, no specific procedures were performed regarding the determination as to whether vendors were suspended or debarred. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new procurement procedure to ensure vendors are not suspended or debarred, was prepared and implemented effective in fiscal 2026. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed, Name of Contact Person: Jacquelyn Farrell, LCSW Executive Director 203-624-2600x204 jfarrell@familyct.org Projected Completion Date: Immediately

A procurement checklist will be developed to require proper documentation if utilizing Federal Funds. The checklist will list specific thresholds for procurement based on funding type, and whether the procurement is construction related and list requirements and thresholds for the construction activity. A new vendor checklist will also be developed to ensure that the vendor is not debarred and/or suspended prior to conducting business with them. The checklist will also list other relevant documents that will be needed prior to first payment. The anticipated completion date will be 9/30/2026.

Finding 2025-001 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition and Context: During our testing as it related to compliance with procurement we noted that an expense for engineering services for the Waste Water Treatment Assessment services charged to the major program would have required a formal bidding process as the project exceeded the simplified acquisition threshold. The Town had selected the engineering company for “On Call” engineering services as it related to the DPW through a request for qualifications process. The contract does include as part of the services to be provided Waste Water Treatment Assessment services. However, the contract is not specific to federally funded projects. The Town of Medfield had submitted the request for qualifications documentation as well as the executed contracted for “On Call” services to both the Town’s consulting service and the pass through entity for approval of the Waste Water Treatment Assessment. The pass through entity and the pass through entities Auditors did not have any concerns with the request for qualifications as it relates to the Waste Water Treatment Assessment project. Questioned Costs: $175,500 Cause: Based on the judgement of the pass through entity (Norfolk County) and their auditors, the Town was approved to procure engineering services for the Waste Water Treatment Assessment as part of a larger “On Call” services contract. The Town did select the contractor through a competitive request for qualifications process, but did not initiate a separate procurement for the sub-project. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2024-001 Recommendation: Going forward, the Town of Medfield should consider a separate bidding process for expenses related to federal grant funds. Responsible for Corrective Plan: Contact Person: Kristine Trierweiler, Town Administrator Estimated Completion Date: May 7th, 2026 Action Taken: On an ongoing basis, the Town will initiate separate procurements for projects covered under federal grants.

This is the result of procurement transactions fonded with the ARPA Coronavirus State and Local Recovery Funds. The County did not conduct procurement transactions in a manner providing fair and open competition on two constrnction contracts. The comptrollers office will enhance procurement policies and review of federal grant funded purchases.