Corrective Action Plans

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

- We now implemented a best practice to require that a contractor submitting a bid or sub awardees affirms that they are not debarred, suspended or otherwise ineligible for federal funding during contracting with IFPA. We save their email response and include the file in any future audits. - As a best practice, we will make every attempt to avoid sole-sourcing. In cases where solesourcing is unavoidable, we will document and file the sole-source justification of services to be procured from contractors or sub awardees in which it applies in the form of former contacts or otherwise written confirmation - As a result, we will draft and adopt a formal procurement policy.

Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures related to procurement in March of 2024. See FY23 Corrective Action Plan. However, the one procurement sample that was cited as not including “documentation of bidding, alternative price quotes or sole source documentation” contained a sole source justification that was developed before implementation of the FY23 Corrective Action Plan. The sole source justification was based on the specialized knowledge and specific expertise. Procurement samples for purchases or contracts after the implementation of the FY23 Corrective Action Plan, show compliance of adequate bidding, price quotes or sole source documentation consistent with 2 CFR 200. The NWIFC will continue to implement the FY23 Corrective Action Plan, by requiring NWIFC managers and their staff to be responsible for soliciting bids or developing sole source justifications for procurements and contracts consistent with 2 CFR 200. The Contract Specialist will ensure that bid solicitations and sole source justifications are properly documented and filed with each contract. Similarly, the audit noted that certain suspension and debarment samples selected, before the FY23 Corrective Action Plan was implemented in March 2024, lacked documentation of a suspension and debarment review prior to doing business with vendors. In response, the FY23 Corrective Action Plan, put into effect in March 2024, included measures to ensure that both new vendor and annual reviews are documented. The Accounts Payable department will continue to conduct suspension and debarment reviews for all new vendors before conducting business and perform annual reviews of all vendors, in line with the FY23 Corrective Action Plan. Anticipated completion date: Completed March 2024.

Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.

Finding: The Foundation is responsible for implementing policies, including internal controls, that are designed to provide reasonable assurance regarding the achievement of the following objectives: effectiveness and efficiency of operations, reliability of reporting for internal and external use; and compliance with applicable laws and regulations. During the audit, it was identified that the federal procurement and other policies surrounding federal funds, as required under the Uniform Guidance (2 CFR Part 200), were not fully implemented until the latter part of the year. Consequently, certain procedures conducted prior to the implementation of the new policies did not incorporate all required federal standards. Corrective Action Taken: Management, under the leadership of the Chief Executive Officer, Josh Goldberg, has developed and fully implemented a comprehensive procurement policy compliant with federal regulations under the Uniform Guidance (2 CFR Part 200) starting October 2024. This policy ensures adherence to all required federal standards, including competitive bidding, vendor selection, conflict of interest, and documentation requirements. Staff have been thoroughly trained on the new procedures to ensure consistent application across the organization. Internal monitoring controls are in place to ensure ongoing compliance for all federally funded procurements. Management also maintains active communication with awarding agencies to ensure a clear understanding and proper implementation of all compliance requirements related to federal funds. Completion Date: January 1, 2025

U.S. Department of the Treasury AUDIT FINDINGS: Finding Reference Number: 2024-001 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 fiscal 2024 did not specify a micro-purchase or small purchase threshold above which written quotes would be required. Additionally, a written policy for ensuring vendors are not suspended or debarred was not included in the existing policy and therefore this process was not being executed in a consistent manner. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new Uniform Guidance-compliant procurement policy, including a process to ensure vendors are not debarred, was prepared and implemented in January 2025. 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

Finding 2024-004 Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Lincoln’s 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 is working with our current auditors to update the Town’s procurement policies to be in compliance with Uniform Guidance. Name of Contact Person John Cimino, Finance Director Projected Completion Date 6/30/2026

The American Immunization Registry Association (AIRA) respectfully submits the following corrective action plan for the year ending September 30, 2024. Independent public accounting firm: HAN GROUP, LLC, Washington, DC Audit period: Year ending September 30, 2024 The finding from the year ending September 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2024-001 – Procurement, Suspension and Debarment. Audit Recommendation – Strengthen internal controls over procurement documentation by: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. Management Response – AIRA acknowledges the finding and will implement the following: 1. Procurement Checklist: A standardized procurement checklist will be developed and required for all federally funded procurements. This checklist will help ensure consistent documentation practices and that all necessary procurement steps and compliance elements are completed and retained. Documentation of the completed checklist will be retained in the procurement file. 2. Vendor Eligibility Verification: A formal review process will be established to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. Documentation of the eligibility check will be retained in the procurement file. 3. Staff Training: Targeted training sessions will be conducted on a recurring basis for all staff involved in the procurement process. These trainings will reinforce federal compliance requirements, including proper documentation practices and suspension/debarment verification. Training completion will be tracked and documented. Implementation Timeline – As of March 18, 2025, AIRA has implemented a verification of vendor eligibility process using SAM.gov. The procurement checklist will be developed and implemented by April 30, 2025, and regular trainings will commence by May 31, 2025. We are committed to ensuring full compliance with federal procurement requirements. Please contact the Business and Operations Director at 202-552-0208 with any questions.

Description of Finding The Town’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow their procedures as it relates to the contracts under the procurements applicable to the Town's major programs. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Town will develop a conforming procurement policy including all essential elements. Name of Contact Person Richard Monico, Director of Administration/Procurement Projected Completion Date June 30, 2025

Finding Summary: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids were not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Responsible Individuals: Andre Stringfellow, Chief Financial Officer Corrective Action Plan: Procedures will be developed and staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation. Anticipated Completion Date: August 2025

Audit period: The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule of expenditures of federal awards. Finding 2024-001 – 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: $40,500 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: N/A 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: April 30th, 2025 Action Taken: On an ongoing basis, the Town will initiate separate procurements for projects covered under federal grants.

Finding 2024-003 - Wage Rate Compliance: The District has consulted legal counsel and secured a standardized contract template to be used for construction projects financed with Federal funds. This contract will be implemented consistently moving forward to ensure compliance with applicable wage rate regulations.

Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all current contractors and subcontractors regarding the wage rate requirements for contracts in progress and has implemented additional procedures for future projects effective October 1, 2024. These additional procedures include the Chief School Financial Officer (CSFO), Linda Harper, reviewing all proposed construction contracts for inclusion of the prevailing wage rate clause as part of the bid process prior to expenditures being made. The CSFO will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

The Village Major will continue working with the consultants to update the required policies and procedures to ensure compliance during this next year.

Environmental Protection Agency, passed through State of North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, Debarment Material Weakness Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Jordyne Lee, General Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements. Anticipated Completion Date: December 31, 2025.

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, 2025, reporting period.

We will comply with the procurement policy. I have already submitted the information to ODEW for FY25.

2024-001 Planned Corrective Action Management Comments and Corrective Action: The project manual included in the solicitation issued for construction of the North Brushy Creek Fork Trail Project did contain FHWA Required Contract Provisions that include the wage rate requirements and submission of weekly certified payrolls to the City. City sta􀀁 was requesting the certified payrolls from the construction contractor upon request from TXDOT, the federal funding representative. Therefore, not all weekly payrolls were initially obtained. Upon request of the auditor, all weekly payrolls were obtained from the contractor and no issues were identified. City sta􀀁 has begun implementing a checklist for City sta􀀁 surrounding construction contracts on which Federal funding is involved. In addition, sta􀀁 and third-party representatives will be trained in federal reporting requirements. Proposed Implementation Date of Corrective Action: In process and to be completed by September 30, 2025. Person Responsible for Corrective Action: Chris Brickey, P.E., Capital Projects Manager – Engineering and Capital Projects

Corrective Action Plan We are in the process of updating the Organization’s procurement policy and procedures regarding suspension and debarment requirements. Completion Date Fiscal year end 2025