Corrective Action Plans

Contact Person – Pattie Solberg, City Auditor Corrective Action Plan – The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date – December 1, 2025

Management’s Response: The Association will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.

Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2024 COVID-19 - Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material NoncomplianceFinding Summary: During the course of the engagement, it was identified that the Cooperative's written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative did not follow procurement, suspension, and debarment procedures required under the Uniform Guidance prior to entering into contracts with vendors. Responsible Individuals: Director of Administration Services, General Manager Corrective Action Plan: The Cooperative will update its Board Policy No. 205 to include the requirements of 2 CFR sections 200.318 through 200.326. In addition, the Cooperative will maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2025

2024-002: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School's reasoning for a noncompetitive procurement. Repeat Finding: Similar to prior year finding 2023-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Finding 2024-002 Corrective Action: We will update our procurement policies and procedures to align with the latest Uniform Guidance requirements, including the 2024 updates that mandate documentation of price reasonableness for all micro-purchases. We plan to adopt a standardized coding submission that clearly articulates the various types of purchases and the appropriate documentatoin for each type of purchase. We will adopt regular training sessions for procurement and grant management staff to reinforce comnpliance requirements and proper documentation practices. Person Responsible: Interim CFO - Bruce Tyler and Finance Director - Jason Phillips Timing for Implementation: October 31, 2025

Person responsible for this corrective action plan: Jana Kent, Executive Director Corrective Action Plan: YNHA is developing a suspension and debarment training for all staff and program managers to ensure that suspension and debarment requirements are adhered to and include a search on Sam.gov, as required. Estimated Completion Date: October 31, 2025

Contact Person (s): Jim McCarthy - jim@waterwatch.org ; Neil Brandt – neil@waterwatch.org Corrective actions planned: The following corrective actions are being immediately implemented for contracts in WaterWatch’s restoration program in order to achieve compliance: 1. Language requiring all contractors to comply with the Build America, Buy America (BABA) Act is added to all new WaterWatch contracts and all current contracts via amendment. 2. Language requiring all contractors to comply with federal suspension and debarment contracting standards is added to all new WaterWatch contracts and all current contracts via amendment. 3. WaterWatch will keep formal documentation of debarment searches for all contractors. 4. WaterWatch will keep formal documentation of contractor procurement process in both Southern Oregon and Portland offices. Anticipated completion date: September 1, 2025

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA adopted a new, updated procurement policy in October 2024. PDA worked with Clark Nuber to develop this policy. Anticipated Completion Date: October of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors

Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: The City does not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Finance Officer Corrective Action Plan: The City will establish controls to follow all applicable procurement requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: December 31, 2025

The Organization is in the process of revising its procurement and conflict of interest policies to ensure alignment with the requirements of 2 CFR §§ 200.318 through 200.326. During fiscal year 2026, the Organization will adopt updated written procedures and implement a formal internal control checklist to verify compliance with federal procurement standards across all grant-funded purchases. Staff responsible for procurement will receive training on the revised policies to ensure consistent application moving forward.

Corrective Action Plan: During Q4 2025, Shiloh’s general purchasing policy will be updated to consider the requirements included in 2 CFR 200.328 through 200.326. (Note: This update was originally to be implemented in Q4 2024 but was delayed due to unexpected turnover in the Business Department.)

Program: Summer Food Service Program CFDA: 10.559 Finding Type: Noncompliance / Significant Deficiency Issue: Purchases from two food vendors exceeded the micro-purchase threshold without documented price comparisons or quotations. Management's Response: Response: Management acknowledges the importance of adhering to federal procurement standards, including the requirement for competitive pricing and documentation for purchases exceeding the micro-purchase threshold. Corrective Action Taken: Staff involved in procurement have been trained on 2 CFR 200.318-200.326 to ensure understanding of federal procurement requirements. A procurement forecast is now developed at the beginning of each grant cycle to identify vendors likely to exceed the micro-purchase threshold. . For all vendors expected to exceed $10,000 in purchases, the YMCA will obtain and retain at least three price comparisons or quotations. A procurement checklist and documentation log have been implemented to ensure compliance and audit readiness. Responsible Individuals: Karrie Stanford and Gina Franklin Completion Date: Plan has been implemented as of the date of audit submission.

District has been in discussion with our attorney and have already got a new ordinance written and put into effect as of June 1, 2025. CVDWSD currently has a procurement policy as a ordinance.

2024 – 009 Special Tests and Provisions – Wage Rate Federal Agency: Department of Interior Federal Program Title: Outdoor Recreation Acquisition, Development and Planning ALN: 15.916 Pass-Through Agency: Arizona State Park Trails Pass-Through Number(s): 04-007-652304 Award Number and Period: 04/18/2022-12/31/24 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Condition/Context: There was no support provided for the three out of three contractor vendors with construction work noted on their purchase orders to support compliance with Davis Bacon. Corrective Action Plan: Regarding the wage tests for the Park’s grant, no information was provided to the City from the contractor of employee wages paid by the contractor. An email request and answer from the contractor was forwarded to the auditors, that the contractor was not responsible to report the wages. This in the future will be part of the Grants Coordinator position for Internal Control purposes, to ensure that any future construction contracts include the wage reporting requirements. Anticipated completion date: December 2025 Contact Person: Mr. Joel Kramer, City Manager

Finding Number: 2024-001 Recommendation: Create a procurement policy that meets the requirements detailed in 2 CFR 200.318– 200.327 Action Taken: AANA will implement a new Procurement Policy as it relates to purchases and grants supported by the MAST program. See document “MAST Procurement Policy” Responsible Contact Person for Planned Corrective Action: Dennis Siena Anticipated Completion Date: September 30, 2025

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will adopt a formal Federal procurement policy which includes all elements identified in 2CFR Sections 200.303 and 200.318 through 200.626.

Finding 2024-003 – Material Weakness Award No.: AL No. 15.555 and AL No. 15.074 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The following conditions were noted during the single audit: • The District was not able to provide evidence that procurements for the Mendota Pool Fish Screen and Control Structure Project and Poso Canal Bridge Replacement Project design contractors under AL 15.555 met the requirements for adequate price competition and was unable to provide documentation confirming the sole-source solicitations met the requirements of Uniform Guidance. Specifically the District was unable to provide evidence it received enough statements of qualification to have adequate price competition or complied with one or more provisions of Section 200.210(c) that allows a sole source agreement to occur. It would appear the District would need evidence that the grantor approved the sole source procurement, but was not able to provide documentation of approvals of sole source procurements by the grantors. The District also was unable to provide documentation of the advertisement of the solicitation of requests for qualifications for the Fish Screen and Control Structure Project. • The District was not able to provide adequate documentation that the Mendota Pool Fish Screen and Control Structure Project contract under AL 15.555 and Orestimba Creek Recharge and Recovery Expansion Project contract under AL 15.074 complied with Section 200.327 and appendix II to this part requiring federal contract provisions to be included in the approved contract. This resulted in the District not having evidence that the contractor certified it was in compliance with all required federal provisions. Criteria: Uniform Guidance states the following: • Section 200.318(i) states that “The non-Federal entity 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, contractors selection or rejection, and the basis for the contract price.” • Section 300.320(c) states “There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: (1) The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The procurement transaction can only be fulfilled by a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; (4) The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or (5) After soliciting several sources, competition is determined inadequate. • The provisions of the Brooks Act (49 United State Code, Section 1104) require local agencies to award federally funded engineering and design related contracts, otherwise know as A&E contracts, on the basis of fair and open competitive negotiations, demonstrated competence, and professional qualifications (23 Code of Federal Regulations (CFR), Part 172) at a fair and reasonable price (48 CFR 31.201-3). Both federal regulation and California state law (Government Code 4525-4529 et a) require selection of A&E consultant services on the basis of demonstrated competence and professional qualifications. Procurement by noncompetitive proposals may be used only when the award of a contract is infeasible under small purchase procedures, sealed bids or competitive proposals, as cited above. • Section 200.327 states “The non-federal entity’s contracts must contain the applicable provisions described in appendix II to this part.” Appendix II contains requirements to include in federally funded contracts termination for cause and convenience provisions, Equal Employment Opportunity provisions, Davis-Bacon Act provisions, Contract Work Hours and Safety Standards Act provisions, Clean Air Act provisions, debarment and suspension provisions, Byrd Anti-Lobbying Amendment provisions, and other provisions, as applicable. Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the requirement to maintain documentation indicating the procurement was in compliance with Uniform Guidance Sections 200.318 to 200.327 and appendix II to this part. Context: The original procurement for the consulting firm for the Mendota Pool Fish Screens and Control Structure project was performed in September 2018 and awarded in late October 2018. This procurement precedes the current staff. Staff indicated the grantor approved the Mendota Pool Fish Screen and Control Structure Project sole source procurement and the Board Resolution approving the agreement indicated the grantor approved the sole source procurement, but staff was not able to provide proof of written approval by the grantor. Recommendation: We recommend management implement additional controls over the procurement process that ensures each procurement complies with Uniform Guidance Section 200.318 to 200.326, including training of staff working on procurements of the documentation retention and other requirements under the Uniform Guidance. We further recommend the District establish a procurement folder on its server with subfolder for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals/qualifications with language that satisfies Uniform Guidance requirements, proposals received, executed contracts, certifications of compliance with federal contracting provisions by the contractor if not part of the proposal or executed contracts, documented quantitative and qualitative analysis indicating why the recommended bid was selected for approval, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. If a sole source procurement method is used, documentation showing the sole source procurement is allowable under criteria listed in Section 300.320(c) should be retained. Views of Responsible Officials and Planned Corrective Actions: Management will keep procurement folders on each procurement in the future that includes the confirmation in the recommendation and will consult with Reclamation on whether a contract amendment is necessary to document the federal contract. Estimated Completion Date of Corrective Action: Future procurement projects

The Purchasing Director for the City-Parish has the authority as provided by the Code of Ordinances to approve emergency purchases upon review of the certification of the emergency by the user department. At the beginning of 2024, the Baton Rouge Police Department noted its patrol units were in less than standard conditions and a recent Police Academy graduating class of sworn officers compounded the need for viable units. At the same time, a nationwide supply chain crisis limited the availability of vehicles for purchase. Multiple quote requests from vendors across Louisiana confirmed a lack of available inventory including the Louisiana State Contract vendor as well as a piggyback contract for the Jefferson Parish Sheriff’s Office. After an exhaustive search, a single vendor was located who had an inventory of matching vehicles on hand for offer within a limited time frame. In an effort to not compromise public safety, an emergency purchase was utilized which was signed by both the Police Chief and the Purchasing Director. As required, notice was given by publishing in the newspaper. Expected Implementation Date: June 2025 Contact person: Philip Gore, Interim Director, Purchasing Division

The amendment in question did not constitute a material change in the scope, nature, or intent of the original procurement. The additional funding awarded was consistent with the original services solicited and did not involve new activities or substantially alter the deliverables or performance standards initially procured. As such, the amendment fell within the bounds of the original competitive process and was not required to be procured. The City-Parish procurement policy allows for amendments when they do not exceed the original scope of work or introduce fundamentally different services. The amendment was processed with full documentation of cost reasonableness, continued eligibility under the applicable grant program and internal approval. Therefore, we assert that the contract amendment was executed in accordance with both HUD and local procurement requirements and no formal procurement was necessary. To strengthen internal controls and ensure full alignment with federal procurement requirements, the OCD will document and reinforce internal procedures outlining when procurement is or is not required for amendments within the original scope. Procurement training is ongoing. The OCD staff will conduct refresher training with procurement and program personnel on contract amendment procedures and documentation requirements. Expected Implementation Date: August 2025 Contact person: Kelly LeDuff, Urban Development Director, Office of Community Development

May 27, 2025 U.S. Department of Treasury Tech Goes Home Incorporated respectfully submits the following corrective action plan for the fiscal year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs 50 Washington Street Westborough, Massachusetts 01581 Audit period: The finding from the December 31, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY AND MATERIAL INSTANCE OF NONCOMPLIANCE DEPARTMENT OF TREASURY Passed through Massachusetts Technology Park Corporation d/b/a Massachusetts Technology Collaboration 2024-001 Procurement Policy and Procedures COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, assistance listing number 21.027. Recommendation: Management should develop and implement a procurement policy that aligns with the requirements set forth in 2 CFR §§ 200.317–200.326 of the Uniform Guidance. Action Taken: Management acknowledges the finding and concurs with the recommendation. TGH is in the process of developing and formalizing a comprehensive procurement policy that complies with the procurement standards outlined in 2 CFR §§ 200.317–200.326 of the Uniform Guidance. The policy will address key areas such as allowable procurement methods, competition requirements, contract oversight, and verification against the federal suspension and debarment list. Management anticipates that the procurement policy will be reviewed and approved by the appropriate oversight body by June 30, 2025, and staff will receive training on its implementation shortly thereafter. TGH is committed to strengthening internal controls over procurement to ensure continued compliance with federal requirements. If the U.S. Department of Treasury Massachusetts Technology Park Corporation d/b/a Massachusetts Technology Collaboration has questions regarding this plan, please email Dahlia Bousaid Cox at dahlia@techgoeshome.org. Sincerely yours, Dahlia Bousaid Cox Interim Chief Executive Officer Tech Goes Home Incorporated

Finding 2024-002 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2024 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding Summary: During the course of the engagement, it was identified that the Cooperative’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Denne’ Smith, Chief Financial Officer Corrective Action Plan: The Cooperative will update its written policy to include the requirements of 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: June 30, 2025

Corrective Action Plan Item 2024-002 Special Tests and Provisions - Wage Rate Requirement Responsible Parties: Heath McInnis, Assistant Superintendent The Board will provide assurance that proper prevailing wage requirements are added to construction contracts being paid from Federal funds, and that certified payrolls are maintained for each week in which construction work is performed. These changes will be enacted by July 31, 2025

Management’s Response OPSO acknowledges the finding and appreciates the importance of maintaining documented verification of vendor eligibility and ensuring all federally required provisions are present in contracts funded by federal awards. We would like to clarify that the two vendors in question were not suspended or debarred according to SAM.gov records at the time of the audit. However, OPSO did not retain adequate documentation of the verification performed at the time of procurement, nor did we fully integrate all Appendix II provisions in the contract files reviewed. This deficiency did not result from intentional noncompliance but from gaps in procedural oversight and documentation retention stemming from historical procurement practices and limited internal controls over contract file completeness. Corrective Action Plan To address the finding and ensure full future compliance with 2 CFR § 180.300, § 200.326, and related guidance, OPSO has implemented the following corrective actions: 1. Contract File Documentation Protocol Effective July 1, 2025, all procurement files for federal contracts exceeding $25,000 must include: • A printed or digitally archived screenshot of the SAM.gov record showing the vendor’s exclusion status. • A signed vendor eligibility certification form confirming the entity is not suspended, debarred, or otherwise excluded. • A signed checklist confirming inclusion of required Appendix II contract All contract files will be centrally stored and monitored by OPSO’s Procurement Division. 2. Updated Procurement Templates OPSO has updated all procurement and contracting templates to: • Include the full list of required provisions from Appendix II to Part 200. • Add a standard Suspension and Debarment certification clause. • Automatically require review of the SAM.gov Exclusions List prior to final contract execution. 3. Staff Training and Compliance Oversight All staff involved in procurement and grant-funded contracting were trained on federal procurement standards and suspension and debarment requirements on December 31, 2025. Refresher trainings will occur semi-annually and be required for new staff during onboarding. A pre-award compliance checklist has been instituted to ensure proper documentation and verification steps are followed and archived. 4. Post-Award Compliance Reviews Beginning Q4 of Fiscal Year 2025, OPSO’s Internal Audit and Compliance Division will conduct quarterly reviews of all federal contract files to ensure: • Proper documentation of vendor eligibility. • Compliance with contract content requirements under 2 CFR Part 200. Findings will be reported directly to the Chief Financial Officer and Sheriff for corrective follow-up if deficiencies are found. Conclusion OPSO remains fully committed to upholding all federal procurement and grant compliance standards. While this finding did not result in questioned costs, we recognize the risk it poses and have taken decisive action to enhance internal controls, training, and documentation standards. We appreciate the audit team’s diligence and remain available to provide any further documentation or clarification needed. provisions.

2024-004 The Akron – Canton Regional Airport Authority request wage reports with all projects. The majority of these reports are submitted with pay applications. The standard practice is that the company overseeing the construction management of the projects submits these reports to the Airport. The Airport had a couple projects without a firm overseeing the construction management. There were a few pay applications associated with these projects that the Airport did not receive wage reports and had to request after the fact. The Airport has since involved more staff members to review pay application for required information. Completed June of 2025 James Krum, VP of Finance and Administration