Corrective Action Plans

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.

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.