Corrective Action Plans

YWCA will develop a written procurement policy that conforms with the Uniform Guidance. In addition, we will implement procedures and control processes to retain documentation supporting compliance with major federal compliance requirements regarding suspension and debarment.

2026-004 Procurement Corrective action planned: OMC will follow its current procurement policy and will seek bids for contracts with autorenewals, utilities, and professional services. However, OMC will also review its current procurement policy to see if changes are necessary to reflect the current environment to exclude items such as certain utilities and services from the bid process if such utilities and services are unique and limited to the service area of the health center and if only one option exists or the current vendor is performing sufficiently so that undue burden would be placed on the Organization to switch vendors, then a sole source justification will be documented, in both paper format and electronically so that records are readily available for review. Anticipated completion date: 08/31/2026 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

Contracts will be corrected in ongoing contracting.

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Housing Hope adopted a Procurement Policy that aligns with the Uniform Guidance following year end. The policy was communicated to all staff with purchasing and procurement responsibilities. The policy will be reviewed at least annually to ensure continued compliance with the Uniform Guidance. In addition, management conducts periodic reviews of procurement practices to verify compliance with the Policy. Anticipated completion date: The Procurement Policy was adopted November 2025 by the Board.

9. 2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that satisfy the requirements outlined in 2 CFR 200.318 through 200.327 and 2 CFR 180.220. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its current procurement policies, procedures, and internal controls as they relate to purchases made with federal funds. The University is assessing existing purchasing practices to identify areas where additional documentation, clarification, or controls may be needed to support compliance with applicable federal procurement requirements. As part of this work, management will review responsibilities and coordination among Sponsored Programs, Grant Accounting, the Business Office, Purchasing, and departments responsible for initiating and approving federally funded purchases. The University plans to strengthen and document processes surrounding appropriate approvals, purchasing methods, supporting documentation, vendor review, and other applicable federal requirements. Particular attention will be given to establishing clear ownership and appropriate checkpoints within the purchasing process so that compliance considerations are addressed before federally funded purchases are completed. The Office of Sponsored Programs, in collaboration with the Business Office and other affected departments, will support the review and development of updated procedures and provide guidance and training as processes are established. Management recognizes that strengthening the University's procurement framework will be an ongoing process and will prioritize improvements based on identified risk, operational needs, and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

Finding No.: 2025-013 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002, S403A240002 Area: Procurement and Suspension and Debarment Questioned Costs: $2,284,786 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding cost or price analysis and suspension and debarment requirements. GDOE recognizes that its procurement policies should clearly address the requirement to perform and document cost or price analyses for applicable procurements and contract modifications exceeding the simplified acquisition threshold. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement procedures should be reviewed periodically to ensure that applicable federal requirements are incorporated and that adequate controls are in place to demonstrate compliance. GDOE Supply Management Office will: 1. Review and update procurement policies to address the requirements of 2 CFR 200.324 for cost or price analysis. 2. Establish procedures and standardized documentation for cost or price analyses, including applicable contract modifications. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method, and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to ensure compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will be performed to verify that required cost or price analyses and suspension and debarment verifications are completed and documented.

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services in excess of $15,000, in which Auditor participated and was subsequently provided with the procurement operations and results, complete with Auditor’s own competitors. Vendor/Partner Contracts: The specific vendors and subcontractors were evaluated, vetted, and formally approved by the U.S. Department of Transportation (USDOT) during the competitive application and award phase of the Thriving Communities program. The Regulation: Under 2 CFR 200 (specifically regarding procurement by non-federal entities), if a federal awarding agency explicitly approves specific subrecipients or contractors as part of the federal award, it generally waives the requirement for subsequent competitive procurement for those designated roles. See USDOT-approved budget line items showing the named vendors (see USDOT Approved Budget” attached). All records are on file with the USDOT. Subrecipient/Contractor Monitoring: COMTO provided clear, signed agreements with these preapproved vendors that pass down all federal compliance requirements (e.g., Title VI, civil rights compliance, reporting metrics) required by the Thriving Communities program. Auditor has not clarified exactly which federal or local regulation they believe requires a rebid of USDOT-approved project partners (see executed contracts attached). COMTO does not run a competitive bidding or procurement process to select a subrecipient. They were selected as collaborative partners/sub-awardees and their status as subrecipients was explicitly authorized by the USDOT when they approved our grant award. All records are on file with the USDOT.

Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: Testing of the federal program identified the following: a. The Organization’s formally documented procurement policy is missing one required element as it relates to domestic preferences (2 CFR 200.322). b. Two lease agreements were entered into where the Organization did not follow the procurement process as detailed in the procurement policy. The lease agreements with the vendors were also missing a required contract provision in accordance with Uniform Guidance and there was no review performed by the Organization to ensure the vendors were not suspended or debarred as the lease agreements with the vendors were over $25,000. Corrective Action Plan: Management will implement a checklist to ensure the Procurement Policy is being followed. In addition, management will review the procurement policy elements and update our procurement policy to ensure it incorporates all required elements. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director and Christina Thoelke, Business Manager Anticipated Completion Date: September 2026

Corrective Action Plan Year Ended December 31, 2025 The following is the corrective action plan for Section III - Federal Award Findings and Questioned Costs: Finding 2025-002 Summary of Finding: The USDA requires multiple reports to be submitted each fiscal year. During the current year, certain reports were not submitted to the USDA until after the due date. Corrective Action Plan: Effective immediately, the Nursing Home Administrator will maintain a calendar reminder to ensure notifications are sent after the close of each quarter when the required report is due for submission. Contact Person: Caitlin Delbridge, NHA Westward Heights Care Center Administrator

Procurement Policy – Assistance Listing Number 14.251 Recommendation: We recommend management update the procurement policy to be in line with Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to be in line with Uniform Guidance. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2027

Federal Agency Name: Corporation for National and Community Service Federal Financial Assistance Listing #94.012 Program Name: September 11th National Day of Service and Remembrance Grants Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: The organization’s procurement policy is missing required provisions in accordance with 2 CFR 200.318. For each of the 3 vendors selected for testing there was no documentation retained to support the rationale for the method of procurement. Additionally, the Organization did not retain supporting documentation to substantiate whether consideration was taken whether the vendor was suspended or debarred from doing business with the federal government prior to entering the covered transaction for each of the 3 vendors selected for testing. Corrective Action Plan: Management agrees with the finding and has revised its procurement policies and procedures to strengthen compliance with federal procurement requirements. The organization's Procurement Policy has been updated to incorporate applicable requirements of 2 CFR Part 200, including requirements governing procurement methods, noncompetitive procurements, conflicts of interest, contractor oversight, and suspension and debarment. Management has also implemented a standardized Sole Source Justification and Procurement Record for noncompetitive procurements. The record requires identification of the applicable basis for noncompetitive procurement under 2 CFR §200.320(c), documentation of the programmatic need and procurement rationale, consideration of available alternatives and applicable market research, documentation supporting cost or price reasonableness, suspension and debarment verification when applicable, and required internal approvals. Supporting documentation will be retained with the procurement record. For covered transactions subject to federal suspension and debarment requirements, management will verify the prospective contractor's exclusion status prior to entering into the transaction and retain dated evidence of the verification. Procurement documentation and required compliance reviews will be completed and retained prior to contract execution.

View of Responsible Officials: Management acknowledges the finding and agrees that documentation supporting compliance with procurement requirements was not consistently retained. For the seven disbursements selected for testing, management had established longstanding relationships with the vendors utilized and, in several instances, there were a limited number of vendors capable of providing the specialized equipment and services acquired for the project. Management indicated that procurement procedures were performed during the vendor selection process, including obtaining and evaluating quotes, discussing vendor alternatives, and visiting other healthcare organizations to assess the quality and suitability of certain products before making purchasing decisions. However, many of these activities occurred several years earlier, at the outset of the construction project, and supporting documentation was not maintained in accordance with the Organization's procurement policy and federal documentation requirements. Management agrees with the finding and will implement procedures to ensure procurement activities are conducted and documented in accordance with the Organization's procurement policy and Uniform Guidance requirements. Corrective actions will include establishing a centralized procurement file, providing additional training to personnel responsible for purchasing activities, and implementing supervisory review procedures to ensure that competitive procurement and documentation requirements are consistently met and appropriately retained.

Finding 2025-004 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2025 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance 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 200.327. 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: Kevin Mazure, Brad Essenmacher Corrective Action Plan: The Cooperative will update its written policy 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, 2026

Corrective Action: Management agrees with the finding. Management intends to develop and implement written policies and procedures, provide staff training, and establish a vendor verification process designed to ensure compliance with Uniform Guidance procurement and suspension and debarment requirements. Anticipated Completion Date: December 2026 Personnel Responsible for Corrective Action Plan: Cyndi Hanson, Chief Financial Officer

Management will develop, formally approve, and implement written procurement procedures that comply with the Uniform Guidance procurement standards in 2 CFR §§ 200.317 through 200.327 and will be approved by the Board of Directors.

Regarding Finding 2025-001, pertaining to procurement, the Pennsylvania Broadband Development Authority has determined that the vendor in question was a project manager and did not provide general contracting services. As such, the rules regarding procurement were inapplicable. Please see the attached email from the Pennsylvania Broadband Development Authority. Related to any corrective action regarding this finding, pertaining to any future federal monies, Church of the New Covenant commits to using documented procurement policies which conform to the procurement standards in 2 CFR 200.317 through 200.327. Church of the New Covenant will in the future maintain records which sufficiently detail the history of procurement, including the rationale for procurement method, selection of contract type, contractor selection or rejection, and the basis for contract price. In the future, a staff person will be assigned the responsibility for the implementation of supervisory review procedures, for the review and updating of the procurement policy and procedures, and for the development of a standardized procurement file checklist.

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. One contract tested did not contain all applicable Uniform Guidance contract provisions. In one instance involving contracts exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Corrective Action Plan: KCEC will update its procurement procedures to incorporate applicable Uniform Guidance requirements. Debarment checks will be completed and documented for all vendors prior to contract execution while also ensuring that contracts contain attestation that the vendor affirms they are not disbarred. Contracts will be reviewed to ensure all required federal provisions are included. KCEC's Grant and Compliance accountant will strengthen its contract review process to ensure federal guidelines and language is present and included in contract verbiage by actively participating in contract negotiations between the vendor and KCEC. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

Finding 2025-002 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2025 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding Summary: Corrective Action Plan: Responsible Individuals: 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 200.327. The Cooperative will update its written policy to include the requirements of 2 CFR sections 200.318 through 200.327. Denne’ Smith, Chief Financial Officer Anticipated Completion Date: December 31, 2026

The National Preservation Institute acknowledges the finding related to procurement documentation. While the National Preservation Institute believes its procurement activities were conducted in a manner consistent with Federal requirements, certain documentation necessary to demonstrate compliance was not retained in a manner that readily supported the procurement decisions. Management has reviewed the circumstances surrounding the finding and has reinforced expectations regarding procurement documentation, record retention, and compliance with Federal procurement requirements. Going forward, procurement files associated with federally funded activities will be reviewed to ensure that all required supporting documentation is generated and retained, including documentation supporting the basis for contractor selection, cost or price analyses, procurement method, and any other records required by Uniform Guidance. In addition, the National Preservation Institute will formally adopt a procurement policy designed to align with the procurement standards contained in Uniform Guidance, including requirements related to competition, conflict of interest, documentation, contractor selection, and procurement record retention. Management believes that the combination of a formal procurement policy and enhanced review procedures will strengthen compliance with Federal procurement requirements and ensure that procurement files contain sufficient documentation to support future monitoring, audit, and reporting requests.

Corrective Action Plan for the Calendar Year Ended December 31, 2025 In response to the finding from the Federal Single Audit for the fiscal year ended December 31, 2025. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2025-002- Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will continue to strengthen its processes and internal controls to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained. Christopher Caulfield, Assistant Vice President of Finance, will effectuate the corrective action plan, which will be completed by December 31, 2026. 973-754-2016

Conditions – The Authority has a formalized procurement policy (the policy). However, the policy does not conform to applicable standards under Uniform Guidance because it does not include procedures to ensure the Authority does not enter into covered transactions with entities that are debarred, suspended, or otherwise excluded. We noted during our testing that there was limited documentation of the Authority's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Recommendation – We recommend that management strengthen their formal procurement policy using the guidance of 2 CFR 200.317 – 200.327. Additionally, management should follow this policy when procuring services or property and maintain the related documentation. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. Management is in the process of reviewing and revising its policies. Anticipated Date of Completion – Completed. Action Taken – In regard to the 2025 audit finding Procurement Procedure, the Loop Water Authority recognizes the shortcoming and has implemented the following action to remedy the finding: The sampled contract existed prior to the ARPA procurement requirements. The aforementioned contract was provided to legal representation for confirmation of compliance with all requirements and was stated to be, in compliance. The failure existed at the management level as not confirming SAM.gov or contractual verbiage. The Loop Water Authority corrective action was to hire a full-time Executive Director to provide oversight and operational compliance for all contracts. The Executive Director has implemented a checklist to review all new procurement contracts for compliance using standards from 2 CFR 200.317 – 200.327. Person Responsible for Corrective Action Plan – Jason Hann, Executive Director.

Management agrees with the finding. Management will spend additional time reviewing CFR Part 200 for familiarization. Policy templates will also be reviewed, and assistance will again be requested to develop/finalize the necessary policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: • The District has not formalized and adopted a written procurement policy. • In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. • In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for the vendor selection. Corrective Action Plan: The District will develop and formally adopt a written procurement policy addressing procurement activities involving federal awards and the applicable requirements of the Uniform Guidance. The District will establish procedures to document the procurement method utilized and the basis for vendor selection, verify and retain documentation that vendors subject to federal suspension and debarment requirements are not suspended or debarred from participation in federal programs, and ensure that federally funded contracts include applicable federal contract provisions required by 2 CFR Part 200. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: March 2027

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that procurement procedures and related documentation requirements were not consistently followed and that adequate controls were not in place to ensure compliance with federal procurement standards. Management will conduct a comprehensive review of procurement policies and procedures and will implement formal review requirements for procurement method determinations. To support these efforts, management is hiring a Purchasing Coordinator who will be responsible for all aspects of the Organization’s procurement function and for ensuring that all purchases are conducted in accordance with the Organization’s written procurement policies and the procurement standards of the Office of Management and Budget (OMB) Uniform Guidance (2 CFR 200.317 through 200.327). Additional procedures will require documentation of price reasonableness, competitive quotations, sole-source justifications, and aggregate vendor purchase evaluations, as applicable. The Purchasing Coordinator will determine and document the appropriate procurement method for each purchase, obtain and retain required quotations, and maintain complete procurement files for all purchases charged to federal awards. Personnel involved in purchasing activities will receive additional training on Uniform Guidance procurement requirements, and management will implement monitoring procedures to verify compliance on an ongoing basis. To maintain appropriate segregation of duties, the Accounting Department will independently review procurement files before payment to verify that documentation is complete and that the selected procurement method is appropriate and compliant with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

In 2026, written procedures governing the allowability of costs charged to Federal awards and procurement activities involving Federal funds were developed, documented, and implemented. Responsibility for implementing and maintaining these procedures has been assigned to the Finance Department. The procedures address applicable Federal requirements for determining allowable costs and procurement activities and will be reviewed periodically and updated as necessary to maintain compliance with applicable Federal requirements.