Corrective Action Plans

Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency will revise its procurement policy to fully align with the requirements of 2 CFR Parts 200.317-200.327, including procedures for all required procurement methods. This revision is being coordinated with the broader update to the Fiscal Policy and Procedures Manual currently underway to ensure consistency across all organizational policies. The CFO and CAO will work jointly to implement and monitor corrective actions in cross-functional areas, including timekeeping, payroll documentation, record retention, lease tracking, IT access controls, vendor onboarding, procurement documentation, and personnel training. This shared structure is intended to ensure that policy revisions are supported by clear workflows, staff training, documentation standards, and periodic compliance review. We note that no purchases during the audit period met the threshold requiring formal competitive bidding, and no questioned costs were identified. By September 30, 2026, the Agency will complete updates to procurement procedures.

Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.

Using the DHS Contract Lifecycle Management (CLM) System, the Office of Procurement Services (OPS) reviews all contract requests (new, amendments, renewals, and extensions) for compliance with the State Purchasing Act. During the review, OPS will inform the program of any requests that do not comply with the Procurement Rules and Regulations before the contract is fully executed, providing a list of alternative exempt vendors. The contract will be halted until DHS is notified and approval is granted, or until a solicitation is posted and awarded. Senior-level staff in OPS will also review all requisitions for goods not processed through CLM to ensure that purchases comply with the State Purchasing Act. A spend analysis is conducted on purchases not exempt from the State Purchasing Act to determine whether the associated NIGP Code Category is above or below the bid threshold. If the NIGP Code is or may be above the bid threshold, precautionary steps are taken to ensure that the Department of Human Services remains in compliance with the State Purchasing Act (i.e., suggesting exempt vendors, halting the purchase until DHS is notified and approval is granted, or until a solicitation is posted and awarded).

Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with Build America, Buy America (BABA) Act. Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grantrequired stipulations such as BABA requirements, monitoring, compliance, and documentation. Anticipated completion date: We will develop and approve the updated procurement policy by 7/31/2026.

The Town will revise procurement procedures to ensure that written contracts are executed prior to the commencement of work for material projects. Procedures will include emergency procurement protocols consistent with 2 CFR §200.320(c), requiring written justification and documentation when public exigency is used. Staff will be trained on federal procurement requirements, including contract execution and documentation standards.

The Town of Spruce Pine will update its written procurement policies to fully incorporate current federal procurement standards under 2 CFR §§200.317–200.327 and applicable state procurement regulations. Management will provide training to staff involved in procurement and contract administration. The Town will also establish an annual policy review process to ensure procurement procedures remain current and compliant.

Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, and compliance with applicable requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Policy was voted on by the board and put into place subsequent to year end.

2025-00I Condition: The center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Auditor's Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR §§ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Corrective Action Plan Finding 2025-001 Information on the federal program: Federal Program Name: Congressional Directives Federal Agency: U.S. Department of Health and Human Services Federal Assistant Listing and Title Number: 93.493 Award Year: September 1, 2024 to August 31, 2025 Criteria or Specific Requirement: Procurement, Suspension and Debarment Condition: The District is required to have procedures to ensure vendors are not suspended or debarred prior to charging services to the grant, as well as required to follow their own documented procurement procedures which should conform to the Uniform Guidance procurement standards. Correction Action Planned: The District has reviewed the applicable requirements of the Office of Management and Budget Uniform Guidance for procurement standards, specifically those related to the requirement for procedures to be documented regarding suspension and debarment and noncompetitive procurement. The District acknowledges that their procurement policy does not currently conform to the Uniform Guidance procurement standards, and formal procurement methods were not utilized for certain grant expenses. At the time of procurement, the District operated under the understanding that engagement of a vendor holding a General Services Administration (GSA) contract was consistent with and would satisfy applicable procurement requirements. Upon further review, the District recognizes that this assumption did not, in itself, meet all Uniform Guidance requirements, particularly with respect to documentation and justification of procurement methods. To ensure compliance with Uniform Guidance going forward, the District will implement corrective actions. The District will update the current procurement policy to ensure compliance Uniform Guidance. The District will provide formal training to existing grant Program Managers on Uniform Guidance procurement standards. Additionally, for any new grant opportunities, the grant committee will receive training on Uniform Guidance procurement standards prior to the completion of grant applications. For both existing and future grants, any proposed contracts or purchases exceeding $3,000 will be subject to review by the grant Program Manager (or the Grant Committee lead, if a Program Manager has not yet been assigned) to ensure that the appropriate procurement method is utilized, all required documentation is obtained and retained, and compliance with all applicable procurement standards is verified prior to purchase or execution of any contract. Contact Person (s) Responsible for Corrective Action: Ana Zavala, Chief Financial Officer Anticipated Completion Date: These corrective actions will be implemented immediately, with training completed by May 2026.

Finding: 2025-030 - A review of 17 FY 25 Disaster Grants payments found that 15 payments - (88 percent) lacked adequate supporting documentation. Questioned Costs: Indeterminate Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DMVA concurs with the finding Corrective Action (corrective action planned to ensure compliance with federal regulations and effective management of federal awards, the Finance Office, in conjunction with the Homeland Security Director, will develop and implement written procedures that provide a clear framework for managing federal awards and ensure compliance with federal regulations. DMVA will: • Clearly outline federal requirements under 2 CFR 200.327, 2 CFR 200.403(g), and Homeland Security Acquisition Regulation Class Deviation 15-01. • Specify the documentation required to support reimbursement requests, including expectations related to discrepancies and follow-up actions. • Outline the procedures for Homeland Security for reviewing and certifying work completed by contractors, where applicable, prior to reimbursement to subrecipients. Completion Date (list anticipated completion date): October 31, 2026 Agency Contact (name of person responsible for corrective action): Bryan Fisher

The Town acknowledges the lack of written policy and procedures for expending federal funds and insuring vendors are not debarred, suspended, or ineligible to receive federal funds. The Town shall (1) Update its written procurement policies and procedures to require verification of vendor eligibility through SAM.gov prior to awarding any contract or issuing any purchase order funded with federal awards. (2) Require procurement staff to retain documentation of the suspension and debarment verification. (e.g., dated SAM.gov search results or vendor certifications). (3) Provide training to relevant personnel on federal procurement requirements including suspension and debarment compliance under 2 CFP Part 200.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Action: The City ensures that debarment requirements for prime contractors and subcontractors are met prior to the use of federal funds. Moving forward, the City will expand compliance efforts to include all required parties. Staff will be educated on these requirements, and the City will work with engineers to ensure debarment language is included in project bidding documents and supplementary conditions. Proposed Completion Date: Immediately

2025-005 – Procurement Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations, procedures, and property and equipment management. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026

Community Project Funding/ Congressionally Directed Spending - Construction Community Project Funding – Assistance Listing No. 93.493 Recommendation: We recommend that the Organization formally documents its existing procurement and suspension/debarment practices in written policies that comply with 2 CFR Part 200. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The instance identified by the auditors was related to the Organization not having a written policy that documents its existing procurement and suspension/debarment practices. The Organization has outlined its response in the bullet points below: • The Organization implemented a formal, written policy that details their procurement and suspension/debarment practices and will follow this policy moving forward. Name(s) of the contact person(s) responsible for corrective action: Brian Holcomb, Controller Planned completion date for corrective action plan: Has been implemented If there are questions regarding this plan, please call Brian Holcomb, Controller, at 612-638-4900.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Name of contact person: Michelle Richards – City Clerk/Treasurer Corrective Action: The city will develop a policy to provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and that no award, subaward, contract or agreement is made with any suspended or debarred party. Proposed Completion Date: Fiscal year 2027

2025-003 PREVAILING WAGE U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we noted the Authority did not notify contractors that Federal funds would be in payments. As such, contractors did not include federal prevailing wage language in their bids/contracts, and did not provide weekly certified payroll reports to the Authority. Cause: Management was unaware of the requirements of prevailing wage for federal construction grants, and as such, did not communicate to contractors that federal funds would be utilized. Effect: The Authority was not in compliance with the grant requirements in the OMB Compliance Supplement over prevailing wage requirements for laborers and mechanics. Questioned Costs: Unable to determine. Recommendation: We recommend management obtain a greater understanding of the Compliance Supplement requirements over HUD grants, and implement a review process whereby contracts and invoices are not approved without appropriate prevailing wage consideration and certified payrolls. Action Taken: The Authority will gain a greater understanding of HUD grants, and will implement a review process to ensure prevailing wage requirements are considered prior to approving contracts and invoices. Individual(s) responsible for implementing: Maureen Carpenter, CEO Anticipated Completion Date: September 30, 2026

Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: The District does not have a written procurement policy in place that satifies all provisions of Title 2 CFR Part 200.318 through 200.327. Responsible Individuals: Neil Breidenbach, System Manager Corrective Action Plan: The District will review the requirements of CFR sections 200.318 through 200.327 and update their procurement policy that meets the requirements. Anticipated Completion Date: December 31, 2026

Planned Corrective Action: Management will strengthen procurement policies, procedures, and documentation practices to ensure compliance with Uniform Guidance (2 CFR 200.318–200.327) and TxGMS general procurement standards. Actions will include: updating the procurement policy to clarify procurement methods and dollar thresholds; adopting a standardized procurement justification template for sole source determinations that requires documented rationale and supervisory approval; implementing a required procurement file checklist that documents the procurement method used, vendor selection process, quotes or bids obtained, and retained supporting documentation; instituting supervisory review and sign off of procurement classification and supporting documentation prior to award approval and payment; providing targeted training for Programs, Finance, and Procurement staff on procurement rules, sole source justification, and simplified acquisition documentation requirements; and performing a retrospective review of the two identified procurements to complete or document required supporting evidence and remediate any gaps. Finance will perform periodic testing of procurement files to verify adherence to the updated procedures and report findings to management and the Audit Committee. Responsible Parties: Kyle Bolls, Controller Ryan Parks, CFO Estimated Completion Date: September 30, 2026

Improve Internal Controls over Reporting Name of contact person: Connie DeKemper Anticipated completion date: 12/31/2026 Condition – During our audit, we noted the quarterly report ended March 31, 2025, was not filed. The expenditures for that period were included on the quarterly report ended June 30, 2025. Response - The County is in the process of reviewing the terms of the subrecipient agreement for reporting and is developing systems for timely reporting.

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

Finding 2025-001 - Material Weakness Condition: Two (2) Next-Generation Facility Project (the Project) consulting contracts were procured in compliance with the Federal Transit Administration's (FTA's) procurement guidelines but did not conform with the Caltrans Local Assistance Procedures Manual (LAPM) Sections 10.01 and 10.1.9 of the LAPM, including not including a Public Interest Finding for the sole source procurement of the agreement, and the LeFlore group, LLC non-A&E consultant contract procurement did not comply with Section 10.3 of the LAPM. In addition, a Disadvantaged Business Enterprise goal was not requested nor completed as part of the advertisement for the project, which was required under Section 9.7.2 of the Caltrans LAPM. Recommendation: The Authority add additional language to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the Federal Highway Administration (FHWA). Management's Response: Management will ensure additional language is added to its Procurement Policy documenting the requirement to follow Section 10 of the LAPM and the criteria under which it applies when grants are received from the FHWA. The action will be completed with Board adoption of an updated Procurement Policies and Procedures Manual at or before its regular June 18, 2026, meeting. The contact person responsible for this action is Matthew Mauk, Executive Director, (530) 634-6880.

Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2025-2026

Corrective Action Plan Procurement Finding 2025-006 Roof Above will update the procurement policy to comply with Uniform Grant Guidance to include updated threshold criteria, publicizing bids, and checking for suspension and debarment of contractors. Roof Above will also update the corresponding procurement checklist to align with updated policy. Contact person responsible for corrective action: Kaedon Grinnell, Chief Program Officer Anticipated completion date: June 30, 2026

As part of the Uniform Guidance audit, OU Health will maintain and provide documentation outlining the process by which eligible vendors will be identified and selected. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will update policies in accordance with applicable standards, as well as develop a checklist to document the selection of vendors and the associated purchases made for federal programs. The supporting documentation will be reviewed by management to ensure vendor selection and procurement activities comply with Uniform Guidance requirements. The checklist and all correspondence will be retained with the report and within the Audit Folder.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2022 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Non-Compliance Department’s Management Response: Ventura County Health Care Agency (HCA) management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official record, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: HCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO John Fankhauser, HCA Director Implementation Date: March 2026 – Add documentation of suspension and debarment check for applicable contracts April 2026 – Include applicable provisions described in 2 CFR 200 Appendix II to contracts