Corrective Action Plans

Finding 2025-004 U.S. Department of Agriculture Federal Financial Assistance Listing/ALN #10.855 Distance Learning and Telemedicine Grants Federal Award #IA0714-BI17 2025 Procurement, Suspension and Debarment Material Noncompliance and Material Weakness in Internal Controlover Compliance Criteria: Uniform Guidance and 2 CFR §§ 200.318 through 200.326 establish the procurement standards that non-federal entities (other than states) must follow when expending federal awards. These standards require non-federal entities to maintain written procurement policies and procedures that ensure full and open competition, use of appropriate procurement methods based on dollar thresholds, and inclusion of required contract provisions as outlined in Appendix II to Part 200. Condition: The Hospital does not have a written procurement policy that conforms to the procurement standards under Uniform Guidance and 2 CFR §§ 200.318 through 200.326. In addition, testing of the Hospital’s only procurement transaction during the audit period disclosed the following instances of noncompliance: The procurement method used was not in accordance with Uniform Guidance requirements, as the contract amount exceeded the simplified acquisition threshold and a sealed bid or other allowable competitive procurement method was not obtained. The executed contract did not include all required contract provisions as prescribed by Appendix II to 2 CFR Part 200. Planned Corrective Action: Management is aware of the deficiency of internal control over the procurement, suspension and debarment direct and material requirement and subsequent to fiscal year end has implemented a formal procurement policy. Planned Completion Date: June 30, 2026 Person Responsible: Denise Hook, Chief Financial Officer

The Organization concurs with the finding and is reviewing procurement policies to ensure adequate documentation is maintained.

The District will develop and implement procurement policies and procedure to ensure compliance with 2 CFR section 200.318 to 200.326.

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procurement standards of 2 CFR sections 200.318 through 200.326, and procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200. Specifically, 2 CFR sections 200.430, 200.431, and 200.475 require written policies concerning compensation for personal services, fringe benefits, and travel costs, respectively. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures after yearend that were the policies and procedures followed during the year under audit and meets the requirements of Subparts D and E of 2 CFR Part 200. Contact Person: John Jacques Date of Completion: November 14, 2025

Criteria or Specific Requirement: Nonfederal 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. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures for procurement. Management confirmed policies and procedures were followed and monitored during the construction of the project. Written policies and procedures were completed after year-end. Contact Person: John Jacques Date of Completion: November 14, 2025

Department of Education The Town of Ridgefield respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. COMPLIANCE FINDING SIGNIFICANT DEFICIENCY Procurement and Suspension and Debarment Recommendation: The Town should review its formal procurement policies and revise 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 planned in response to finding: The Town will review its policies to ensure it aligns with 2 CFR sections 200.318 and 200.326. They will communicate with the appropriate personnel any changes to their policies to ensure compliance in the future. Name of the contact person responsible for corrective action: Jill Browne, Director of Finance Planned completion date for corrective action plan: June 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 7AZ300AZ3, 6AZ300400, 7AZ310AZ1 Contact Person: Dominick Ruth, Director of Finance Anticipated Completion Date: July 1, 2025 Planned Corrective Action: Creighton School District #14 will review vendor awards in Visions and ensure that expired awards or awards that do not qualify as a competitive procurement awards are removed from the ERP system. In FY26, and in future the fiscal years, the District will obtain three written quotes for the Nutrition department's purchases from the associated vendor.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Contact Person: Shannon Kavanagh, Executive Director of Business Services Anticipated Completion Date: October 14, 2025 Planned Corrective Action: Upon finding that the District was not compliant with Federal, State, and Board policies and regulations governing procurement, a Request for Procurement was issued for the services received by the awarded vendors. The RFP was issued October 14, 2025. Moving forward, the District is taking additional steps to review the procurement requirements for the purchase of like items over $100,000 with the Executive Director of Business Services, the Assistant Director of Business Services, and the Purchasing Accountant/Buyer. The District will also be reviewing this requirement District‐wide with individuals responsible for purchasing during one of the ten purchasing workgroup meetings annually.

Audit Finding 2025-001 - Procurement and Suspension and Debarment Corrective Action Plan The City will revise its procurement policy and procedures to address all relevant requirements under Uniform Guidance, specifically: . Incorporate written standards of conduct covering conflicts of interest for employees involved in procurement, in accordance with 2 CFR 200.318(c)(1). . Include written policies and procedures requiring affirmative steps to solicit and consider participation by small, minority, women-owned, veteran-owned, and labor surplus area businesses, as specified in 2 CFR 200.321(b). . Add explicit provisions to require sufficient and detailed recordkeeping for all procurement transactions funded with federal awards, addressing the requirements of 2 CFR 200.318(i). Persons responsible for corrective action Jamie Rhodes, Administrative Services Manager Branden Dross, City Administrator Corrective action completion date June 30, 2026

Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend that the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so it is clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Bill Holmgren Planned completion date for corrective action plan: June 30, 2026

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).

To ensure compliance with all procurement regulations and established procedures, the Executive Director of Operations, Alnita Miller, will ensure that procurement procedures are appropriately documented, reviewed and followed for all school food service department purchases; ensuring all inputs entered into the bid analysis summary are complete and accurate. These controls will be implemented forthwith.

Procurement - Special Education Cluster (IDEA) (Significant Deficiency) Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. The Board of Education failed to solicit written quotations (in noncompliance with federal UG for procurements over $10,000) related to a contract paid under the grant. Under local policy, sealed bids should have been obtained for a competitive procurement over $25,000. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education will review its procurement processes to ensure they comply with local policies and federal guidance. Name of Contact Person Christian Strickland, BOE Chief Operating Officer Projected Completion Date June 30, 2025

FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Corrective Action Plan: We will create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200. Proposed Completion Date: March 31, 2026

Department of the Treasury Federal Financial Assistance Listing/ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: The Organization does not have a procurement policy that conforms to applicable standards under Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth in the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement policies required. Responsible Individuals: Steve Kuehneman, Executive Director, Bob Pawlikowski, Director of Finance and the Board of Directors of CARE Communities. Corrective Action Plan: Management agrees with the finding. Management and the Board of Directors have reviewed Eide Bailly’s procurement recommendations and will adopt a Board-approved Procurement Policy that complies with Uniform Guidance. The Organization will apply these procurement requirements to all applicable contracts and will review contracts to ensure inclusion of all provisions required under Uniform Guidance. Anticipated Completion Date: 2026

SPECIAL EDUCATION CLUSTER – PROCUREMENT U.S. Department of Education Special Education Cluster Assistance Listing Number: 84.027 & 84.173 Passed Through Minnesota Department of Education Pass Through Number: H027A220087 Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025 and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – PROCUREMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 93.600 and 93.558 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensure quotes are obtained for all procurements that are above the micro-purchase threshold, and that this process is documented along with their assessments of cost analysis performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all department heads to ensure proper compliance in the utilization and disbursement of federal funds.

Finding: Material weakness in internal control over procurement policies Questioned costs: ALN 81:113 ($31,120) ALN 19.901 ($15,000) Corrective action: While PFI accepts the finding and the rationale for identifying questioned costs based on Uniformed Guidance (UG) requirements for documentation regarding competitive bidding and contract types, it believes there is adequate documentation to justify incurred costs. PFI will update its procurement policy guidelines to reflect current UG requirements to include acquisition thresholds and competitive bidding procedures. Completion Date: February 1, 2026 Responsible Individual: Executive Director

Contact Person(s): Sarat Puthenpura Corrective action planned: ONF is in the process of upgrading its current written procurement policy to better comply with Federal audit requirements. The policy will be updated to include: • Inclusion of services under coverage of the policy • Micro purchase threshold explicitly defined. • Clear provisions for maintaining detailed procurement records including a requirement that such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. • The simplified acquisition threshold explicitly defined and incorporates all relevant elements including sealed bids method. Anticipated completion date: 11/30/25

Formula Grants for Rural Area and Tribal Transit Program Federal Assistance Listing #20.509 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 and state requirements for procurement. The Organization should ensure documents are retained to support whether procurement policies were followed for vendors procured in years past. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review the procurement standards as well as ensure documents are retained to support whether procurement policies were followed. Name(s) of the contact person(s) responsible for corrective action: Carrie Beithon, Director of Financial Services Planned completion date for corrective action plan: 12/31/2026

Finding 2024-011 – Procurement and Suspension and Debarment (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the procurement requirement was met due to staff turnover. Management Response: Management agrees. Corrective action plan: •All procurements now require documentation of vendor eligibility verification (SAM.gov) and compliance with competitive bidding rules. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

Financial leadership of Child Saving Institute Inc. is in the process of developing a new procurement plan that will put the agency in compliance with 2 CFR sections 200.318 and 200.326

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies and procedures to ensure that future awards or contracts with expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Most of the 2024 expenditures were part of contracts that were already in place when the original findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025

We will incorporate oversight of procurement for the agency to our Accounts Payagble Manager’s job duties and in addition revise our protocols and procedures to adhere to procurement standards found in 2 CFR 200.317-200.326 of the Uniform Guidance. The protocols and procedures will include the following methods of procurement: o Micro-purchases (≤ $10,000): Award without competitive quotations if the price is reasonable; distribute purchases equitably among qualified suppliers. o Small purchases ($10,000–$250,000): Obtain price or rate quotations from at least two qualified sources; document quotes and selection rationale. o Sealed bids (≥ $250,000): Publicly solicit bids; award to the lowest responsible bidder. o Competitive proposals (≥ $250,000): Use when sealed bids are not appropriate; publicize RFPs and evaluate proposals based on predetermined factors o Non-competitive proposals (sole source): Use only when justified (e.g., single source, emergency, federal authorization, inadequate competition). o Maintain Oversight of Contractors to ensure contractors perform according to contract terms. o Record Keeping including: Rationale for method used, selection of contract, selection and rejection of contractor o Training - Provide training to all staff responsible for procurement on the updated policy and procedures.