Corrective Action Plans

The Clinic will review the procurement standards set forth at 2 CFR part 200 and has updated our procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award. The anticipated completion date is 09/30/2025.

The City of Bardstown places a high priority on fiar and equitable purchasing practices. The General Bidding Statue (KRS 424.260) governs purchases made during the normal course of business. The City acknowledges the need to adopt a written purchasing policy to set qualifications and procedures when federal funds are being utilized. A purchasing policy is currently being drafted to adopt procurement standards found in 2 CFR 200.317 through 200.326. This policy will be presented to council and adopted prior to February 28, 2025.

Management concurs with this finding. Management has taken steps to review and revise its procurement policies to comply with state and local laws, the standards of the CFO, as well as current operating procedures. The fining relates to contracts that were originally procured prior to the change in policies, with only renewals in the financial statement periods. Going forward, Management will document basis for procurement for renewals of contracts that originated prior to the new policies and procedures implementation.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Cheryl Burt, Director of Purchasing; Courtney Pina, Executive Director of Finance Anticipated Completion Date: Ongoing Planned Corrective Action: Issue Identified – The District failed to follow Federal, State, and Board policies and regulations governing procurement when procuring a multi‐year professional development support services contract for $111,200. Instead of issuing a formal procurement process, the District used quotes, which did not meet compliance requirements under 2 CFR §§200.318–200.326. Actions Taken to Address the Finding 1. Immediate Remedial Actions o Contract Review: Conducted a thorough review of the contract in question and determined steps to ensure compliance with applicable policies. o Internal Notification: Informed all relevant staff and departments about the compliance violation to prevent similar issues in the future. 2. Policy Review and Alignment o Procurement Policy Review: Conducted a comprehensive review of internal procurement policies to ensure alignment with federal requirements outlined in 2 CFR §§200.318–200.326, as well as applicable state and board requirements. o Threshold Verification: Confirmed that all documented thresholds for procurement types (e.g., formal procurement, quotes) are clearly stated in district policies to ensure consistency and compliance. Actions Planned to Prevent Future Occurrences 1. Training and Awareness o Staff Training: Implement mandatory training for staff involved in procurement processes to ensure familiarity with federal, state, and board regulations. Training sessions will emphasize formal procurement thresholds and the procedures for multi‐year contracts. o Annual Refresher Training: Conduct annual training sessions to maintain staff awareness of procurement requirements and reinforce adherence. 2. Strengthening Internal Controls o Requisition Review: Implement an enhanced approval process requiring multiple levels of review for all procurement transactions exceeding $50,000 to ensure compliance before purchase. o Checklist Requirement: Provide approvers with a compliance checklist verifying adherence to federal, state, and board procurement requirements before approving requisitions. 3. Ongoing Monitoring o Quarterly Audits: Schedule quarterly internal audits of procurement transactions to verify compliance with established policies and identify any gaps early.

Description of Finding: The City’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 agrees with this finding. Corrective Action: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place until June 2024. Name of Contact Person: Jared Schmitt, Chief Financial Officer Projected Completion Date: June 30, 2025

Description of Finding: The Board of Education failed to solicit quotations related to a contract paid under the grant, in noncompliance with federal/local policy. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will review existing processes and contracts to ensure procurements are taking place in compliance with local policies and federal guidance. Name of Contact Person: Lunda Asmani, Chief Financial Officer, Board of Education Projected Completion Date: June 30, 2025

Finding 2024-004 Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: During the course of the engagement in testing of procurement, suspension and debarment it was identified that the School’s micro-purchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Brandon Lunak, Superintendent Corrective Action Plan: The District will update their procurement policy for federal programs to be in compliance with all areas as identified in 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: June 30, 2025

Finding Number: 2024-001 Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Contact Person: Jeremy Bow, Director of Finance Anticipated Completion Date: August 12, 2024 Planned Corrective Action: In May of 2020, amid the urgent health and safety impacts of the global Covid-19 pandemic, Emerge closed its emergency shelter facility in order to transition to the use of a hotel to provide a non-congregate shelter setting for its Participants. In the urgency to make the transition and the uncertainty of the duration of stay, Emerge did not perform a SAM.gov review of the hotel for suspension or debarment, as federal funds were not anticipated to be utilized at the time. In April 2022, Emerge surpassed the $25,000 threshold for federal funds paid to this vendor during a fiscal year. Having previously been operating out of the hotel for nearly 2 years prior, the need for a SAM.gov review was overlooked at that time and was not identified on the audits for either fiscal year 2022 or 2023. When notified of the deficiency on August 12, 2024, during initial field work for the audit of fiscal year 2024, Emerge took same-day action to resolve the previous oversight. On August 12, 2024 Emerge performed the necessary check via SAM.gov and confirmed the vendor hotel was free from suspension or debarment. Concurrently, Emerge revised its Procurement Policy to specifically require compliance with Federal Acquisition Regulation Systems - 2 CFR §180.300 & §180.995. Per Emerge Procurement Policy, revised August 2024: “Any Agency procurement action which will utilize federal or sub-federal funds, in full or in part, shall be done so in compliance with Federal Acquisition Regulation Systems - 48 CFR §2 Subpart 2.1, 2 CFR §200 Subpart D, and 2 CFR §180.300 & §180.995 as required by federal regulation. Compliance with this and all other Federal guidance shall be the shared responsibility of the Chief Executive Officer, Senior Leadership, and the Director of Finance. Copies of these regulations shall be maintained by the Agency for reference.” It is Emerge’s perspective that appropriate action has been taken in order to substantially mitigate the risk of recurrence based on the revisions to its Procurement Policy and the internal reviews of both the revised policy and the audit finding with Senior Leadership.

The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.

2024‐001 Procurement and Suspension and Debarment Person Responsible for Corrective Action: Lark Reynolds, Business Administrator Correction Action Planned: (1) The District management will review procurement policies with staff. (2) Timely action will be taken to solicit bids for contracts that exceeds District thresholds. (3) To ensure full and open competition takes place, management will routinely review spending reports. Anticipate Completion Date: November 30, 2024

The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District will work with the contractor to obtain and review the certified payrolls to determine the contractor is in compliance.

Child Nutrition Cluster - Assistance Listing Nos. 10.553, 10.555, 10.559 Recommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review the Sole Soure form on an annual basis to make sure the form has not expired. Name(s) of the contact person(s) responsible for corrective action: Debrah Jones, Director of Strategic Sourcing and Contract Management (SSCM) Planned completion date for corrective action plan: 12/31/2024

2024‐001 Special Tests and Provision – Wage Rate Requirements Person Responsible for Corrective Action: Jeff Barben, Business Administrator Correction Action Planned: The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable. Anticipate Completion Date: November 30, 2024

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding streams are blended. The district has already started communication to relay that federal prevailing wage rates should have been utilized. Responsible Person: Nicole Eilola, Shared Services Business Manager & Stacy Price, Superintendent. Anticipated Completion Date: Immediate

Management response/corrective action plan: Efficiency Maine has delegated a staff person to work with outside counsel to revise our procurement policy as it relates to federal funds in order to properly address all requirements of the Uniform Guidance.

October 17, 2024 Cognizant or Oversight Agency for Audit: Department of Elementary and Secondary Education (DESE) Worcester Cuftural Academy Charter Public School respectfully submits the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA, 01581 Audit period: July 1, 2023 through June 30,2024. The findings from the October 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2024-001 Massachusetts Teachers’ Retirement System (MERS) Enrollment. Recommendation: Management should ensue that proper controls are in place and operating effectively to ensure that that all MTRS eligible employees are fully enrolled within thirty days of their start date. We recommend management add enrollment of MTRS for eligible employees to its onboarding checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-002 Massachusetts Teachers’ Retirement Board (MTRB) Remittances Recommendation: Management should ensure that proper controls are in place and operating effectively to ensure all MTRS payroll withholdings are remitted timely. We recommend management add MTRB remittances to its monthly closing checklist. Action Token: We concur with the recommendation, and it was implemented effective September 1, 2024. 2024-003 Written Procurement Policy Recommendation: Management revise their poiicy to comply with current standards under the Uniform Guidance. Action Token: We concur with the recommendation, and it will be implemented effective January 1, 2025. If the Department of Elementary and Secondary Education (DESE) has questions regarding this plan, please call Erika Browning, 508-347-0252. Sincerely yours, Signature: Title: Tina Krasnecky, VP of Finance

Finding No.: 2023-025 AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1: The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Finding No.: 2023-025, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance is warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Finding No.: 2023-025, continued AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Procurement and Suspension and Debarment Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 2: DPW, TSD-Highway Branch and the Procurement Services Division respectfully disagrees with this finding. A review of the procurement file confirmed that the Bid Opening Summary Sheet was maintained as part of the official bid package and procurement record for this solicitation. Procurement Services has located the Bid Opening Summary Sheet and confirmed that it accurately documents the bid opening results in accordance with applicable procurement requirements. The document remains in the procurement file and is available for review. A copy has been provided for reference. Based on the existence and availability of this document, Procurement Services respectfully requests reconsideration of this finding. The supporting documentation identified as missing was maintained within the procurement file and was available for audit review. While Procurement Services disagrees with this portion of the finding, it remains committed to maintaining complete procurement records and will continue reviewing internal recordkeeping practices to ensure procurement files are organized, complete, and readily accessible for audit and compliance purposes. Proposed Completion Date: Ongoing

Finding No.: 2023-019 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (G. Cruz): The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance are warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Condition 2 (E. Cabrera / N. Karakaya / G. Cruz): For TAP sample selections (FG26100012, FG26100002, 1901210068, 2001210031, and FG26100021), the Office of Grants Management (OGM) agrees with this finding and concurs that a formal procedure for verifying suspension and debarment status was not documented during FY2023, especially as this procurement aspect was not enforced by the Division of Procurement Services. However, management is not aware of any instances in which the listed contracts or subawards were issued to entities that were suspended, debarred, or otherwise excluded from participation in federally funded programs. All goods and services were received, and all expenditures were incurred for allowable program purposes. Accordingly, OGM believes the finding represents a control and compliance deficiency rather than an instance of unallowable costs. OGM has begun implementing procedures requiring SAM.gov verification and retention of supporting documentation prior to entering into covered transactions, especially due to a more recent procurement purchase. OGM kindly seeks the auditor’s discretion in changing the questioned costs to the amount of zero, due to it being more of an internal control issue rather than an allowability issue. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: For the CIP sample selection (FC26050009), The Capital Improvement Program (CIP) agrees with the finding and that it did not verify if the firm in question was excluded or disqualified at the time of procurement. The Division of Procurement Services has recently begun requiring agencies to provide search results on SAM.gov Exclusions for the processing of contracts moving forward. CIP will follow this new protocol and include it in the standard documents for all construction and non-construction contracts. To prevent recurrence, CIP will implement the following actions: • CIP will include “Verification of suspension and debarment status” as a required item under Contract Documents on CIP’s contract templates • Staff Training and Awareness o CIP will train staff members to utilize the SAM.gov Exclusions page to search for vendors and print proof of verification. o CIP will ensure that all staff members are familiar with the new protocol with Procurement Services. • Monitoring and Verification o CIP will conduct reviews of new contracts and processing change orders to ensure that this new requirement is met. Additionally, the Procurement Services Division agrees that vendor eligibility was not verified in accordance with 2 CFR Part 180 prior to the covered transactions identified by the auditors. To address this issue, Procurement Services has incorporated suspension and debarment verification into its procurement review process. For federally funded covered transactions, expenditure authorities will be required to provide documentation from the System for Award Management (SAM.gov) verifying that the vendor is not suspended or debarred. This documentation must be submitted with the procurement package and retained in the procurement file prior to award. Procurement Services will review the documentation as part of its procurement review process and will provide additional guidance to procurement personnel and expenditure authorities regarding federal suspension and debarment requirements. Finding No.: 2023-019, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $270,553 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Geraldine Cruz, Procurement Services Director / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: These measures are intended to improve compliance with federal requirements and strengthen procurement documentation and oversight. Proposed Completion Date: Ongoing

Finding No.: 2023-010 AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1: The Procurement Services Division respectfully disagrees with this finding. Procurement Services agrees that the Commonwealth should periodically review its procurement regulations to ensure continued consistency with applicable federal requirements. However, Procurement Services notes that the Procurement Regulations currently establish procurement thresholds and procedures for locally funded procurements and procurements funded through a combination of local and federal funds. Procurements exceeding applicable small purchase thresholds are required to proceed through other procurement methods authorized under the Procurement Regulations, including competitive sealed bidding or other approved procurement methods, as applicable. Procurement Services further notes that procurements exceeding the applicable small purchase thresholds are governed by other provisions of the Procurement Regulations and are therefore not without regulatory direction. Accordingly, Procurement Services does not fully concur that the regulations are inconsistent as described in the finding. Finding No.: 2023-010, continued AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Nevertheless, Procurement Services recognizes the importance of ensuring that procurement regulations clearly align with applicable federal requirements and are sufficiently clear to avoid differing interpretations. Procurement Services is currently reviewing the applicable regulations, policies, and procedures with legal counsel to determine whether revisions, clarifications, or additional guidance are warranted. Due to the resignation of the Assistant Attorney General previously assigned to Procurement Services, this review will continue with newly assigned legal counsel. Any amendments to the Procurement Regulations will require legal review, drafting, public notice, and formal adoption before they can take effect. Procurement Services will also continue monitoring updates to federal procurement requirements and will incorporate any necessary changes into its policies, procedures, and guidance. These efforts will help improve clarity, consistency, and compliance with applicable procurement requirements. Proposed Completion Date: Ongoing Condition 2: CNMI NAP agrees with this finding. The issue occurred because the previous policies and procedures did not fully document the three allowable verification methods under 2 CFR 180.300 for covered transactions ≥ $25,000. As a result of repeat findings, CNMI NAP developed and implemented the updated “SOP for Procurement of Goods and Servicesv.3”, which explicitly requires verification of vendors in the SAM.gov exclusions list prior to award (Section 4.1 and 4.3) and after contract execution, in full compliance with 2 CFR 200.214 and 2 CFR 180.300. This SOP was approved and effective 5/1/25 and is available for review upon request. Additional step taken by CNMI NAP is to continue adhering to the “CNMI NAP Suspension and Debarment SOP” that requires a screen-print documentation and annual reviews. This SOP was approved on 9/24/24 and is available for review upon request. Finding No.: 2023-010, continued AL Program: 10.539 – Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: $684,138 Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: To prevent recurrence, CNMI NAP will deliver targeted training to all procurement, finance, and program staff on the updated SOPs, continue quarterly internal reviews of procurement files using new Google Sheet tracking system to verify ongoing SAM.gov compliance. Full staff training and first quarterly review will be completed by 9/30/26. Additionally, Procurement Services agrees that vendor eligibility was not verified in accordance with 2 CFR Part 180 prior to the covered transactions identified by the auditors. To address this issue, Procurement Services has incorporated suspension and debarment verification into its procurement review process. For federally funded covered transactions, expenditure authorities will be required to provide documentation from the System for Award Management (SAM.gov) verifying that the vendor is not suspended or debarred. This documentation must be submitted with the procurement package and retained in the procurement file prior to award. Procurement Services will review the documentation as part of its procurement review process and will provide additional guidance to procurement personnel and expenditure authorities regarding federal suspension and debarment requirements. These measures are intended to improve compliance with federal requirements and strengthen procurement documentation and oversight. Proposed Completion Date: Completed

CORRECTIVE ACTION PLAN (Concerning Finding 2023-007) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-007 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and drafted, has had approved, and has implemented the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024

CORRECTIVE ACTION PLAN (Concerning Finding 2023-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-004 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and is using the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024.

Reference Number: 2023-05 Finding Type: Significant Deficiency in Internal Control Over Compliance Description of Finding: The Organization did not follow required procurement procedures for subrecipient transactions. Though a procurement policy exists for the Organization, there was no enforcement of this policy for the federal program. Failure to follow a formal procurement policy causes the Organization to be out of compliance with Uniform Guidance and/or grant requirements and increases the likelihood of disallowance of costs. Statement of Concurrence: Management agrees with the finding, however the subrecipient was formally designated budget for the federal program by the pass-through grantor which is why a formal procurement process was not followed. The subrecipient received the same allocated federal funds for the same services provided in the prior year. Corrective Action: The Organization will review internal policies and procedures and ensure that it follows procurement practice for subrecipients under 2 CFR Sections 200.318 – 200.326. Completion Date: March 31, 2026 Name of Contact Person: Maureen Thomas Chief Financial Officer 917-405-7185 maureen@frfive.org

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Procurement documentation did not consistently evidence compliance with internal policy and 2 CFR §§200.318–200.326. Status: Corrective Action Taken Corrective action planned: Voices of Tomorrow will implement procurement software to automate workflows and approval processes for procurement purchases. Voices of Tomorrow will • Revise and formalize procurement policy to align fully with Uniform Guidance requirements.Implement a standardized procurement documentation checklist requiring evidence of procurement method, cost/price analysis, and approvals. • Require CFO pre-approval for federally funded procurements above established thresholds. • Conduct staff training on federal procurement standards. • Implement quarterly internal procurement compliance reviews. Anticipated completion date: April 2026: Policy revision and training completed within 60 days; quarterly reviews beginning next fiscal quarter.

RMIPA will strictly enforce contractors to submit wage-rate compliance documentation as a condition for invoice payment. This reporting requirement will be formally integrated into contract oversight practices.

Corrective Actions Planned To address the deficiency in internal controls over compliance with respect to procurement, CHC will implement the following corrective actions: CHC will develop and implement a written procurement policy that conforms to the Uniform Guidance.; CHC will ensure sta􀀁 receive adequate training on the procurement policy and the required methods of procurement to be made when making procurements with federal awards. Responsible Person(s): CHC President, Rob Dibble as Primary; CHC Vice President Betsy Gordon as Backup Corrective Action Plan Dates: Schedule implementation starts: February 1, 2026; Staff training starts: March 1, 2026; Review process in effect starts: April 1, 2026