Corrective Action Plans

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.

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding Lincoln Public Schools procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management will update Lincoln Public Schools’ procurement policies to include all essential elements to be in compliance with Uniform Guidance.

Corrective Action Plans Finding 2025-001 – Noncompliant procurement policy Corrective Action Plan: The Village will update its written procurement policy to comply with applicable State, local, and tribal laws and regulations and with Federal requirements under 2 CFR §200.317–200.326. In addition, the Village will train personnel on the updated policy. This policy will apply to all purchases of goods, services, and construction funded in whole or in part by Federal awards administered by Village of Hazel Crest, including subrecipients and contractors, unless superseded by more restrictive State, local, or tribal law. Person(s) Responsible: Amanda Page-Horvet, Accounting Supervisor Timing for Implementation: Fiscal Year 2027

Finding: 2025-002 Federal Agency Name: U.S. Department of Treasury Assistance Listing Number(s): 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Finding Summary: 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. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the Non-Federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. It was noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Responsible Individuals: Kyle Wilmot, Canyon County Controller. Corrective Action Plan: Members of the audit office will review each vendor in the SAM.gov database to ensure that they are not suspended, debarred or otherwise excluded. The search of these entity(s) will then be saved to the shared drive for the upcoming ACFR season and the supervisor will be notified of the search to ensure that the files have been properly saved. Anticipated Completion Date: Canyon County will complete the corrective actions for the September 30, 2026, reporting period.

Item: 2025-001 Assistance Listing Number: 93.185 Program: Immunization Research, Demonstration, Public Information and Education Training and Clinical Improvement Projects Federal Agency: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: NH23IP922665 Award Year: August 2024 to July 2029 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Name of Contact Person: Rebecca Coyle, Executive Director Phone Number: (202) 552-0208 Anticipated Completion Date Completed April 2025 Views of Responsible Officials and Corrective Actions: In April 2025, a standardized procurement checklist and a formal review process were established and are maintained to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds.

Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. Plan – The District’s Director of Maintenance, Operations & Risk Management will ensure certified payrolls are submitted with invoices and a copy of the submissions to the US Department of Labor are attached to final pay invoice. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official

II. Findings and Questioned Costs Related to Federal and State Awards Finding Number: 2025‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: - Mandatory documentation of quotes for applicable procurements - Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

Federal Grantor: Department of Agriculture, Pass-Through: Nebraska Department of Education Program: Child Nutrition Cluster, Special Education Cluster Award No. and Year: 13898414/13897314/47600262900 and 2024, 24-6406-00-19-028-0001/24- 6408-00-19-028-0001/24-6411-00-19-028-0001/24-6412-00-19-028-0001/24-6418-132-28-0001P and 2024 Federal Assistance Listing Number: 10.553/10.555/10.559/10.582, 84.027/84.173 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Corrective Action: Management will work with the School Board to update the current procurement policy to include all requirements in 2 CRF 200. Name of Contact Person: Cindy Miserez, Controller (531) 299-9891 cynthia.miserez@ops.org Project Completion Date: June 30, 2026

FINDING 2025-002: Wage Rate Compliance (Repeated 2024-003) Response: The vendors noted in the audit had completed their work before the conclusion of the fiscal year 2024 audit, and the District was unable to obtain all required payroll and wage-rate documentation from those contractors before the 2023-2024 audit was finalized. To prevent recurrence, the following procedures will be implemented: • A contractor checklist will be implemented to document the type of work to be performed, the funding source, and whether Davis-Bacon wage requirements or Montana prevailing wage rates apply before work begins. • Accounts payable staff will verify that all required contractor documentation is received and retained before final payment is issued.

US Department of Treasury Passed through Colorado Department of Human Services Federal Financial Assistance Listing 21.027 Award 24 IBEH 18932 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In our testing of procurement, suspension and debarment it was identified that the Organization did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326 implemented at the beginning of the fiscal year. In addition, there was no formal review of vendors to ensure they are not suspended or debarred prior to entering into transactions. Corrective Action Plan: Both of these two deficiencies will be dealt with through an updated procurement policy as well as a check list to ensure contracts comply with all federal guidelines. In addition, all processes needed to ensure compliance will be updated or created as needed. This recommendation has been implemented last fiscal year, however the deficiency remains as the corrective action wasn’t in place for the entire fiscal year. Responsible Individual(s): Karen DeGroot, Director of Finance Anticipated Completion Date: July 2025

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of West Warwick’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The error will be corrected as of the beginning for fiscal year ending June 30, 2027. We will add the paragraph to our existing purchasing policy. This must be done by resolution and given the timeline that takes, we anticipate having this implemented the end of June 2026. Name of Contact Person Kristen Benoit, Finance Director Projected Completion Date 7/1/2026

February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Controller General. The Corrective Action Plan, submitted by the City of Richardson more specifically, responds to the Report and outlines the City’s corrective action plans to address the finding. We again thank Crowe LLP for their hard work in this matter. This single audit has and will continue to serve as a roadmap for future financial operations. Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency In two out of seven selections tested for required certified payrolls for contactor or subcontractor work performed during the fiscal year end September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Response: The City acknowledges that the required supporting documentation was not available at the time compliance testwork was completed by Crowe LLP. The City recognizes its responsibility to obtain and review certified payroll records from contractors and subcontractors for all laborers working on City grant funded projects to ensure wages and fringe benefits are paid in compliance with the Davis-Bacon Act. Corrective Action Plan: The City has an established Grants Management Policy and quarterly reporting from departments stating compliance with grant requirements. To strengthen compliance and address the documentation deficiency identified in the audit finding, the City will conduct mandatory training sessions with designated grant personnel in each department to reinforce policy requirements, required documentation standards, and applicable federal and state regulations, including certified payroll monitoring requirements where applicable. Training will be completed by June 30, 2026, and will be provided annually thereafter.The City will implement a grant review process that includes a master checklist to assist departments in verifying compliance prior to processing payments. The checklist will include verification that required supporting documentation, including certified payroll records when applicable, has been received, reviewed, and approved. Implementation of this checklist will occur by March 31, 2026. A centralized electronic repository will be established to allow Finance access to grant agreements, supporting documentation and relate records maintained by City departments. This control will be implemented by March 31, 2026. Additional internal controls will be incorporated into the financial software system to ensure that all required supporting documentation is attached and reviewed prior to payment approval. This control will be implemented by March 31, 2026. The City will conduct periodic internal compliance review testing of grants, including verification of required labor compliance documentation where applicable, to confirm ongoing adherence to federal and state regulations. Pre-award and post-award meetings will be held between Finance and the respective grant departments to establish reporting parameters, documentation requirements, monitoring responsibilities and compliance expectations prior to project implementation. When bids are solicited that include grant funding, the City will continue to communicate to all prospective bidders that compliance with all applicable federal and state laws and regulations, including labor standard requirements when applicable, is a condition of award. Bid documents will include a sample copy of the U.S. Department of Labor Davis-Bacon and Related Acts Weekly Certified Payroll form. Contact Person Responsible/Anticipated Completion Date: The Finance Director is responsible for oversight of this corrective action plan, with day-to-day management and implementation delegated to the Assistant Director of Finance. Implementation of these corrective actions is scheduled to begin immediately, with full completion anticipated by June 30, 2026. Once implemented, the procedures will be monitored on an ongoing basis to ensure continued compliance and to prevent recurrence of the finding.

Finding 2025-004 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507, 95-6000807 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Department’s Management Response: The County Executive Office agrees with the recommendation to strengthen its internal controls to ensure compliance with wage rate requirements. View of Responsible Officials and Corrective Action: The County Executive Office Community Development Division will conduct a comprehensive review and update of its Federal Labor Standards Policy and Procedure (FLSPP), with completion targeted no later than July 1, 2026. The updated FLSPP will include a requirement for County staff to obtain and retain certified payroll submissions monthly for all construction activities subject to prevailing wage requirements. Although the formal policy update will not be effective until July 1, staff will begin implementing this control immediately. Name of Responsible Persons: Kimberlee Albers, Deputy Executive Officer Tracy McAulay, Housing Solutions Director Ying Vang, Management Analyst (Community Development Block Grant) Michael Skinner, Management Analyst (HOME Investment Partnerships Program) Implementation Date: April 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Water Conservation Grant Assistance Listing Number: 21.027 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 6, 2026 Planned Corrective Action: The District has designed and implemented policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. The Federal Programs Director and Procurement Clerk will check each vendor exceeding the formal procurement threshold for suspension or debarment.

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management compose a procurement policy with the criteria as set out in 2 CFR sections 200.318 and 200.326. and review the conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR section 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will compose a procurement policy in line with compliance requirements and review and edit the conflict of interest policy to be in compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

March, 3, 2026 U.S. Department of Health and Human Services Dimock Community Foundation, Inc. and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc., 50 Washington Street, Westborough, MA 01581 Audit period: July 1, 2024 - June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD FINDING Material Instance of Non-Compliance: Finding 2025-001: Congressional Directives 2025-001 Assistance Listing Number 93.493 Community Project Funding/CDS Recommendation: We recommend that the Agency adhere to their procurement policy that aligns with the requirments set forth in 2 CFR 200.318-200.326 Action Taken: The procurement of construction services funded through this award was done in early 2023 and preceded Dimock's updated procurement policy which calls for competitive bidding. It also preceded changes in procurement leadership. Subsequent procurement for services have since been subject to competitive bidding by Dimock consistent with CFR 200.318-200.326. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call Luis Rivera, CFO at 617-442-8800. Sincerely, Luis Rivera, CFO

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: During most of the fiscal year (July through April), the City monitored certified payroll reports (CPRs) monthly as part of its construction oversight procedures. Documentation of this monitoring was maintained through email communications and supporting records. In April 2025, following the FY24 Single Audit, the City evaluated its procedures and implemented enhanced controls to better align with federal requirements by requiring weekly monitoring and tracking of CPR submissions. These enhanced procedures were implemented to strengthen internal controls over compliance with federal prevailing wage requirements. Beginning in May 2025, CHA Consulting (formerly Falcon Engineering), the City’s outside consultant, began providing a weekly certified payroll tracking spreadsheet and the requested payroll documentation for selected contractors to the City’s Project Manager for review. The City documented the receipt, review, and follow-up actions through email correspondence and maintained supporting records of these activities. In addition, Public Works staff and the City’s consultants responsible for contract administration and labor compliance monitoring were provided updated guidance regarding federal prevailing wage requirements, including the requirement for weekly certified payroll submissions and documentation of review. Project Manager oversight was incorporated into the process to verify the accuracy of the certified payroll tracking log and ensure that reviews are performed consistently. This oversight provides an additional level of verification that monitoring procedures are conducted in accordance with federal requirements. Although the City enhanced its monitoring procedures, contractors and subcontractors did not always submit certified payroll reports within seven days as required under 29 CFR §3.4. The City continues to reinforce timely submission requirements with contractors and monitors compliance through the weekly tracking process. When certified payroll submissions are not received within the required timeframe, the City follows up with the contractor requesting immediate submission and documents the corrective actions taken. The City remains committed to strengthening its monitoring procedures to ensure timely submission, tracking, and documented review of certified payroll reports. In the event of payroll delinquencies, the City will take appropriate follow-up actions with contractors and may withhold progress payments when necessary to enforce compliance. In addition, the City is implementing new contract provisions in federally funded Public Works contracts to establish clear authority and enforce compliance with federal labor standards. These provisions include: • Requiring weekly certified payroll reporting in accordance with federal regulations • Authorizing the withholding of progress payments for non-compliance • Requiring contractors to communicate labor compliance requirements to all subcontractors • Requiring the use of electronic certified payroll reporting systems, where applicable • Allowing the City to conduct payroll audits and worker interviews as permitted under federal labor compliance regulations These contract provisions are intended to further strengthen the City’s internal controls and ensure compliance with federal prevailing wage requirements on federally funded projects. The City will continue to monitor the effectiveness of these procedures and will update its internal controls as necessary to ensure ongoing compliance with federal labor compliance requirements. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2026

Finding 2025-002 Significant deficiency in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: Management will revise the organization's procurement policy to amend the current dollar threshold, which was determined to be overly restrictive and inconsistent with operational needs and federal procurement standards under 2 CFR Part 200. The updated threshold will align with the Uniform Guidance requirements and provide clear guidance for competitive procurement processes. In addition, the organization will implement a standardized Vendor Justification Form. This form will be required for applicable purchases and will document the rationale for vendor selection, including the price analysis, sole source justification (if applicable), and confirmation that the procurement procedures were followed in accordance with federal requirements. These corrective actions are intended to strengthen internal controls over procurement, improve documentation consistency, and ensure compliance with 2 CFR 200 requirements. Anticipated completion date: August 31, 2026

February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Controller General. The Corrective Action Plan, submitted by the City of Richardson more specifically, responds to the Report and outlines the City’s corrective action plans to address the finding. We again thank Crowe LLP for their hard work in this matter. This single audit has and will continue to serve as a roadmap for future financial operations. Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency In two out of seven selections tested for required certified payrolls for contactor or subcontractor work performed during the fiscal year end September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Response: The City acknowledges that the required supporting documentation was not available at the time compliance testwork was completed by Crowe LLP. The City recognizes its responsibility to obtain and review certified payroll records from contractors and subcontractors for all laborers working on City grant funded projects to ensure wages and fringe benefits are paid in compliance with the Davis-Bacon Act. Corrective Action Plan: The City has an established Grants Management Policy and quarterly reporting from departments stating compliance with grant requirements. To strengthen compliance and address the documentation deficiency identified in the audit finding, the City will conduct mandatory training sessions with designated grant personnel in each department to reinforce policy requirements, required documentation standards, and applicable federal and state regulations, including certified payroll monitoring requirements where applicable. Training will be completed by June 30, 2026, and will be provided annually thereafter.The City will implement a grant review process that includes a master checklist to assist departments in verifying compliance prior to processing payments. The checklist will include verification that required supporting documentation, including certified payroll records when applicable, has been received, reviewed, and approved. Implementation of this checklist will occur by March 31, 2026. A centralized electronic repository will be established to allow Finance access to grant agreements, supporting documentation and relate records maintained by City departments. This control will be implemented by March 31, 2026. Additional internal controls will be incorporated into the financial software system to ensure that all required supporting documentation is attached and reviewed prior to payment approval. This control will be implemented by March 31, 2026. The City will conduct periodic internal compliance review testing of grants, including verification of required labor compliance documentation where applicable, to confirm ongoing adherence to federal and state regulations. Pre-award and post-award meetings will be held between Finance and the respective grant departments to establish reporting parameters, documentation requirements, monitoring responsibilities and compliance expectations prior to project implementation. When bids are solicited that include grant funding, the City will continue to communicate to all prospective bidders that compliance with all applicable federal and state laws and regulations, including labor standard requirements when applicable, is a condition of award. Bid documents will include a sample copy of the U.S. Department of Labor Davis-Bacon and Related Acts Weekly Certified Payroll form. Contact Person Responsible/Anticipated Completion Date: The Finance Director is responsible for oversight of this corrective action plan, with day-to-day management and implementation delegated to the Assistant Director of Finance. Implementation of these corrective actions is scheduled to begin immediately, with full completion anticipated by June 30, 2026. Once implemented, the procedures will be monitored on an ongoing basis to ensure continued compliance and to prevent recurrence of the finding.

Finding Summary: During the course of the engagement, Eide Bailly identified that the District’s procurement policy was not fully in compliance with all of the Uniform Guidance standards. Responsible Individuals: Rhandi Knutson, Director Corrective Action Plan: A procurement policy that is fully in compliance with Uniform Guidance will be approved and implemented. Anticipated Completion Date: June 30, 2026

The Village Mayor will provide an updated policy to be approved by the Village Board in 2026.

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