Corrective Action Plans

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

As requested, Management provides the following responses to the audit findings for the fiscal year ended December 31, 2024. The Organization acknowledges the findings and is committed to strengthening internal controls, improving compliance with Uniform Guidance requirements, and enhancing oversight of federal award expenditures. 1. Use of Inappropriate Procurement Methods Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management concurs with the audit finding that procurement methods exceeding applicable thresholds were not consistently followed in accordance with established procurement policies and Uniform Guidance requirements, despite the existence of a formal written procurement policy. This issue was primarily due to inconsistent awareness and application of procurement requirements among staff and supervisors across multiple program sites. In addition, there was no standardized verification step within the procurement workflow, and supervisory oversight was not consistently applied. This finding represents a repeat issue from prior year finding 2023-001. Corrective Action Plan - Management has implemented and will continue to strengthen the following controls: - Mandatory training on federal procurement requirements under 2 CFR §§ 200.318 200.326 for all staff involved in purchasing activities. - Implementation of a standardized procurement workflow requiring documented approval and verification prior to purchase execution. - Strengthening supervisory oversight and monitoring of procurement activities across all program sites. - Centralized retention of procurement documentation to ensure completeness and audit readiness. These corrective actions were initiated beginning October 10, 2025, and will be fully integrated into all future grant-funded operations. 2. Conflict of Interest Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management acknowledges the observation regarding a potential conflict of interest involving an individual engaged to oversee fiscal operations under the federal grant. The individual was selected through a delegated implementation group and included in budget approval discussions based on qualifications, experience, and trusted standing within the organization and community. Compensation was established at a minimal rate relative to the fiscal agent budget. However, Management recognizes that the circumstances created the appearance of a conflict of interest, and that adequate written disclosure and recusal documentation were not maintained. Corrective Action Plan - Management will implement the following corrective measures: - Adoption of a formal conflict of interest policy aligned with 2 CFR § 200.318(c)(1). - Annual conflict of interest disclosures for all board members, staff, and grant-related personnel. - Mandatory written recusal procedures for individuals with actual or potential conflicts of interest. - Formal documentation and retention of all disclosures and recusals in compliance files. These procedures will be implemented for all current and future federal awards. 3. Failure to Reasonably Consolidate Procurements Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Management acknowledges that procurement activities across multiple program sites were not consistently consolidated, resulting in fragmented purchasing and missed opportunities for cost efficiency. This occurred due to the decentralized structure of operations, lack of centralized procurement oversight, and absence of a formal process to identify and aggregate similar purchases across locations. Corrective Action Plan - Management will implement the following improvements: - Establishment of a centralized procurement function to oversee all purchasing activities across program sites. - Implementation of procurement planning procedures to identify and consolidate similar purchases in advance. - Use of technology systems to track, monitor, and aggregate procurement activity across all sites. - Assignment or hiring of personnel with procurement expertise to provide oversight and training.

Corrective action taken On June 2, 2025, the Board approved revised Policy F2.01 v.01, Procurement for Product or Services, which requires competitive proposals for contracted services, documented selection criteria, and retention of bid responses and award decisions. Effective September 1, 2026, C-WHO adopted Procedure SOP F2.01 v.01, Procurement Under Federal Awards, approved by the Chief Executive Officer and the Director of Finance. The procedure supplements Policy F2.01 v.01 and applies to any purchase charged in whole or in part to a federal award. SOP F2.01 v.01: • incorporates 2 CFR 200.317 through 200.327 and Appendix II to Part 200, as adopted by HHS at 2 CFR Part 300; • sets procurement methods by the current federal thresholds (micro-purchase, small purchase with at least three written quotes, and sealed bids or publicized proposals above the simplified acquisition threshold); • limits noncompetitive procurement to the circumstances in 2 CFR 200.320(c), documented on a Sole Source Justification form approved before commitment; • requires SAM.gov exclusion verification before any covered transaction of $25,000 or more (2 CFR Part 180), and an LEIE check for health care service providers; • establishes written conflict-of-interest standards, including disclosure, recusal, and disinterested Board approval for related-party procurements; • requires cost or price analysis above the simplified acquisition threshold and documented price reasonableness for all federally funded purchases; • requires a Federal Procurement Checklist, completed by a preparer and signed by a separate reviewer, before a contract is signed, a purchase order is issued, or federal funds are charged; and • credits discounts and rebates on federally funded purchases to the award under 2 CFR 200.406.

Federal Agency Name: U.S. Department of Homeland Security, Federal Emergency Management Agency Passed Through South Dakota Office of Emergency Management Assistance Listing Number: #97.047 Program Name: BRIC: Building Resilient Infrastructure and Communities Finding Summary: The City has not adopted a formal policy related to procurement and does not have a control in place to monitor if the contractor was suspended or debarred from doing federal contract work. Corrective Action Plan: We are in the process of establishing a policy that will include federal guidelines along with state requirements. Responsible Individuals: Katie Rencountre Finance Officer Anticipated Completion Date: December 31, 2026

The County will ensure that the Wage Rate Requirements for Federal grants are being used and reported accordingly. A copy of ODOT Quality Assurance Program will be obtained and referenced for all federal projects.

Procurement procedures have been reiterated with staff members and enhanced to include quotes and bids as necessary. Responsible Official: Director of Finance Expected Completion Date: Completed.

Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

Finding 2023-005 ● Condition: There are no written policies and procedures for allowable costs/cost principles, cash management, procurement and suspension and debarment requirements. ● Cause: The Organization does not have a process for reviewing their accounting policies and procedures manual on a regular basis to ensure written procedures conform to Uniform Guidance requirements. ● Corrective Action Plan: Management agrees with the finding and they will evaluate our findings to determine an appropriate corrective action. Financial policies and procedures will be created and implemented. Annual schedule of expenditures will be created by Executive Director or Bookkeeper and reviewed by Board of Directors. Contact Person: Kirsten Jurcek Anticipated Date of Completion: September 1, 2026

IC 2024-005 Wage Rate Requirements -Review of Certified Payroll Reports For each week in which work was performed under the contract or subcontract, the required certified payroll reports were not fo1mally reviewed. a) We concur with IC 2024-005 that for each week in which work was perfo1med, the required certified payroll reports were not formally reviewed by the County. b) Management concurs with this finding. We will work to develop policies and procedures for ensuring that an appropriate level of senior staff or management review certified payroll reports independently of any reviews performed by contracted engineering firms. James Shubert, County Manager and Beverly York, Senior Accounting Supervisor, are responsible for the corrective action process and anticipate resolution by June 30, 2025.

IC 2024-004 Wage Rate Requirements - Contract Language Required prevailing wage rate clauses were not included in the contract or subcontract. a) We concur with IC 2024-004 that the required language was not included in the contract or subcontract. b) Management concurs with this finding. We will work to develop policies and procedures for ensuring that contracts subject to the Wage Rate Requirements include in the contract language the required prevailing wage rate clauses in accordance with the Uniform Guidance. James Shubert, County Manager and Beverly York, Senior Accounting Supervisor, are responsible for the corrective action process and anticipate resolution by June 30, 2025 .

The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The City will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The policy was revised at the end of the 2025 Fiscal Year. Additionally, a new and additional review process was put into place prior toentering a requisition for approval. This process requires all necessary documentation be furnished to the finance office prior to the requisition being approved. Completion Date: 7/16/2025

2024-003 – Significant Deficiency in Internal Control over Compliance and Other Matters – Special Tests and Provisions Name of Contact Person: Mariya Lovishchuk, Development Director Corrective Action: This was a clerical error issue. Davis Bacon Wages were paid throughout the entire project and certified payroll was provided. However, the original construction contract did not include the correct prevailing wage language. Prevailing wages requirement was discussed and agreed upon prior to issuance of contract, but wrong language was inserted by mistake. Upon discovery of the wrong language, contract amendment was immediately issued to rectify. Proposed Completion Date: Already complete

The Organization will develop and implement written procurement policies and procedures that comply with Uniform Guidance and ensure consistent application across all procurement activities.

Corrective Action Plan Finding 2024-002 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.

The Town Supervisor will provide an updated policy to be approved by the Town Board in 2025.