Corrective Action Plans

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

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.

Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a Suspension and Debarment certification from the contractor. Anticipated Completion Date: April 30, 2026

2025-002 US Department of Education Material Weakness in Internal Control over Compliance Material Noncompliance Procurement Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over procurement requirements. Corrective Action: One City adopted a new procurement policy and while it was implemented, documentation that the procedures were performed were lacking. In addition, One City has developed a training tool so that all staff who have purchasing authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

2025-002 Procurement Supporting Documentation Planned Corrective Action Plan: Heartwood will review federal grant requirements then will ensure that policies and procedures are in compliance with those requirements. Finally, documentation obtained during required procedures, will be centrally located to demonstrate compliance. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Sherri Sampson, Executive Director

Corrective Actions: Housing Authority of the City of Baldwin Park (HACBP) is committed to full compliance with all CDBG reporting requirements and will ensure that future submissions are accurate, timely, and properly documented. HACBP has implemented the following corrective actions: • Established an internal reporting calendar with earlier internal deadlines to ensure adequate time for review and submission. • Documented key reporting procedures to strengthen continuity and reduce reliance on individual staff knowledge. • Initiated cross training to ensure multiple staff members can support CDBG reporting functions as needed. • Implemented automated reminders and tracking tools to improve oversight of reporting cycles. Name of Responsible Person: Okina Dor, Director of Community Development Ryan Mulligan, Housing Manager

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Special Education Cluster – Assistance Listing No. 84.027 Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Action Plan: CCPS Purchasing Department will make the following changes to our current purchasing policy manual to comply with the Audit recommendation above: Noncompetitive bidding (written justification and purchase desc. Docs require) $ 0 - 5K threshold. Informal bidding (3) price quotes required for $5k - $25,000 purchase threshold with no exceptions for MOI. Formal Bidding required at 25K or greater (ITB, RFP, RFQ’s etc) Require purchase justification for all purchases regardless of dollar threshold Require authorized signature approval based on our current dollar threshold for all purchases Name(s) of the contact person(s) responsible for corrective action: Nelson E. Sample, CPPO, Procurement Manager Planned completion date for corrective action plan: No later than June 30,2026

City Clerk will be putting the Grant award Policies and Procedures in place

FINDING 2025-004 Finding Subject: Special Education Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district will implement procedures for Procurement, Suspension and Debarment by following the listed steps: 1. Three quotes will be obtained for procurements between $50,000 to $150,000 by the district and contract be awarded. 2. Verification of Suspension and Debarment will be performed by a member of the business office in System for Award Management (SAM) or the district will collect the certification from the entity prior to entering into transactions with the selected entity. Anticipated Completion Date: 3/31/2026

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA)- Procurement and Suspension and Debarment Federal Agency: Department of Education Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Procurement and Suspension and Debarment compliance requirements. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: We will establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: June 30, 2026

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026