Corrective Action Plans

Description of Corrective Action Plan: For any future projects funded with federal money, the City will ensure the federal procurement standards are followed. Anticipated Completion Date: Immediately, will be considered for any future procurements done with federal funds.

See the Corrective action plant for chart/table

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.

The University agrees with the finding. Management drafted and formally adopted a Uniform Guidance-compliant procurement policy and SAM.gov policy, and training was provided to all staff. See the separate Corrective Action Plan for full details.

The District will draft, approve, and implement written procurement procedures for federal-award procurements and communicate those procedures to the Board of Trustees, management, and personnel or consultants involved in procurement and contract administration.

Finding 2025-005: Noncompliance over Procurement Name of Contact: Chris Pallister, Executive Director Corrective Action: Management will establish and maintain written procurement procedures as specified in the Uniform Guidance procurement standards. For purchases and contracts exceeding $50,000 annually the Organization will publish RFP’s on SAM.gov at least 60 days prior to the project start date. The RFP’s will include the following aspects: • Scope of Work (SOW) or Performance Work Statement (PWS): The RFP should clearly define the project objectives, tasks, and expected deliverables. • Instructions to Bidders: Detail how proposals must be formatted, page limits, and precise submission directions. • Evaluation Criteria: State how bids will be scored (e.g., technical approach, past performance, and price weighting). • Federal Provisions: Include required federal clauses (such as Buy American requirements or Uniform Guidance standards. Any proposals received in response to the RFP will be considered. Proposed Completion Date: November 15, 2026.

Views of Responsible Officials: Management acknowledges the finding and agrees that certain procurement files requested during the audit could not be located or produced in complete form. Management believes that procurement activities were conducted in accordance with organizational policies and applicable Federal requirements at the time the transactions occurred. However, following the rapid and significant reductions in force resulting from the termination of U.S. Government funding, not all procurement responsibilities and records were fully transitioned to remaining personnel. Functions were discontinued on an accelerated timeline, resulting in procurement documentation being maintained across multiple systems and storage locations rather than within a single centralized repository. Consequently, certain supporting records could not be readily retrieved during the audit.Management has initiated a comprehensive revision of its procurement policy and related procedures. The revised policy will require centralized storage of procurement documentation and establish clearer accountability for records management. In addition, roles and responsibilities will be more clearly defined within the organization's current structure to promote consistency, continuity, and accessibility of procurement records going forward.

Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the federal law and standards identified in 2 CFR 200.318 through 2 CFR 200.327. A procurement policy that aligns with these federal requirements is currently being developed. Name(s) of the contact person(s) responsible for corrective action: Lynn Lowrie Planned completion date for corrective action plan: Policy has been drafted and is under internal review. This will be finalized during the November 2026 Board Meeting.

2025-002: Procurement and Suspension and Debarment Statement of Condition: The Organization did not appropriately monitor expenditures for the vendor tested to trigger verification of the vendor status of suspension or debarment prior to the expenditures reaching the $25,000 covered transaction threshold. Additionally, the Organization’s procurement policy did not fully comply with the federal procurement standards outlined in the Uniform Guidance. Management Response and Corrective Action Plan: The Organization has revised its existing vendor policies and procedures to ensure it complies with the federal procurement standards outlined in the Uniform Guidance, including the testing of vendor status for suspension or debarment prior to engaging in any federal award-funded transactions with excluded parties. Responsibility of: Controller, Jennifer Laret and Chief Financial Officer, Jill Borovansky Planned Implementation Date of Corrective Action Plan: 2026 Audit

Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement, Suspension and Debarment Condition: The Village's procurement policy does not comply with the procurement requirements of the Uniform Guidance. The policy does not include written conflict of interest standards applicable to employees, officers, or agents involved in the selection, award, or administration of contracts funded with federal awards. The policy does not establish a simplified acquisition threshold for formal procurement procedures, to align with the federal procurement methods established under the Uniform Guidance. The Village contracted with a third-party administrator who provided the appropriate services related to procurement for this grant program. Corrective Action: Management agrees with the finding and will make efforts to implement a formal procurement policy. Person Responsible For Corrective Action: April Bruhn, Clerk/Treasurer Anticipated Completion Date: December 31, 2026

Finding 2025-002 Finding Type: Material Weakness in Internal Control Over Compliance and Instance of Immaterial Noncompliance Compliance Requirement: Procurement and suspension and debarment Corrective Action Planned Willame􀆩e Health Council will develop, approve, and implement wri􀆩en procurement policies and procedures that conform to the Uniform Guidance procurement standards outlined in 2 CFR §200.318 through §200.327 Procurement Standards. Person(s) Responsible • Josie Silverman-Méndez, Executive Director • Julie Bennett, Finance Manager Anticipated Completion Date • October 31, 2026

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

The town will update policies and procedures so that all contracts going forward will have the provisions outline in Appendex II to 2 CFR Part 200 and make sure that the documentation of the required contract clauses is in accordance with the Uniform Guidance, particularly as it relastes to Contract Work Hours and Safety Standards Act and the Clean Air Act and the Federal Water Pollution Control Act. Planned Impletmentation Date of Corrective Action: 9/16/26

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2025-005 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants – Assistance Listing No. 14.251 Recommendation: We recommend the Organization implement a formal reporting calendar and review control process to track due dates, ensure timely submission, and retain documentation of report filings in accordance with federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a formal reporting calendar and enhanced its review procedures to track filing deadlines, support timely submission of required reports, and retain documentation of filings in accordance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: David Court, Resource Development Director Planned completion date for corrective action plan: June 30, 2026

Management and the City Council will create and approve a written procurement policy that meets the requirements for Uniform Guidance. Additionally, City personnel will make every effort to familiarize themselves with the rules of the Federal Awards programs. Responsible Person: Magdlin Wurst Anticipated Completion Date: December 31, 2026

Management Response: Management has reviewed Finding 2025-001 and concurs with the auditor’s observations. Management recognizes that the exceptions resulted from incomplete procurement documentation and inconsistent use of the required Federal contract provisions and procurement file checklists. Context and corrective actions: • The omission of the Federal contract provisions required by Appendix II to 2 CFR Part 200 was identified through monitoring performed by the grant administrator on behalf of the pass-through entity. Management initiated remediation during the audit period and has amended the affected contracts to include the applicable provisions. Management will also complete a review of active federally funded contracts by September 30, 2026, to confirm that required provisions are included. • One contract lacked documentation demonstrating that the procurement was conducted in a manner providing full and open competition. The vendor relationship predated the grant award; however, management acknowledges that the existing relationship did not, by itself, demonstrate compliance with the applicable procurement documentation requirements. For future federally funded procurements, including procurements involving existing vendors, management will retain documentation of the procurement method, competition performed, and supporting rationale. • For future procurements, the procurement file must include documented evidence of the required price or cost analysis and suspension and debarment verification before contract award or renewal. These requirements will be incorporated into a standardized Federal procurement checklist, as outlined below, with documented review and approval by the Director of Finance and COO. • Management will provide procurement compliance training to relevant personnel by September 10, 2026 and will perform periodic monitoring of federally funded procurement files. Monitoring results will be reported to Board of Directors, and identified exceptions will be tracked through resolution. • The seven exceptions involved four contracts valued below $50,000, two contracts valued between $50,000 and $100,000, and one contract valued above $100,000. These amounts provide context regarding the potential dollar magnitude of the exceptions but do not change management’s obligation to maintain complete procurement documentation and comply with applicable Federal requirements. • Based on the auditor’s procedures, no questioned costs resulted from this finding, and the costs tested were allowable under the grant and otherwise properly supported. Management nevertheless recognizes the importance of addressing the procurement documentation gaps and believes the corrective actions described above will strengthen compliance, improve oversight, and reduce the risk of recurrence. • Management will Develop and Implement Comprehensive Federal Procurement Compliance Checklist. o The Organization has developed a single, comprehensive Federal Procurement Compliance Checklist to be completed for all covered procurements. This checklist ensures compliance with 2 CFR Part 200 (Uniform Guidance) across all identified deficiency areas. The checklist includes: o Federal Contracts Provisions Section (including all contract provisions required by Appendix II to 2 CFR Part 200) o Full and Open Competition Section (including threshold determination, type of procurement method, evidence of public posting, responses, and evaluation of vendors, or a documented Sole Source procurement approval) o Price/Cost Analysis Section (including analysis method, documentation analysis was performed, and evaluation that proposed cost is reasonable). o Suspension and Debarment Verification Section: documented SAM.gov database search, and documentation of escalation if a vendor is found to be on the exclusion list. o The checklist will be integrated into standard procurement workflows to ensure automatic compliance. o Completed checklist must be signed off by the Director of Finance and COO. All documentation referenced in the checklist (competition records, cost analysis, debarment verification) must be retained with the procurement file. o Organization finalized the comprehensive checklist by August 31, 2026 and provided training to all procurement staff by September 10, 2026. The checklist will be required for all new procurements effective September 1, 2026. For all contracts entered into prior to September 1, 2026 that did not comply with the provisions in Appendix II to 2 CFR Part 200, the organization will complete retroactive documentation to the extent possible and execute amendments to incorporate missing Federal provisions by September 30, 2026. Anticipated Completion Date: August 31, 2026 (checklist development); September 30, 2026 (retroactive compliance and amendments) Responsible Party: Daniel Wilmot, Director of Finance

Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.

Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with vendors, contractors, or subrecipients. Criteria Organizations that receive federal funding are generally required, under 2 CFR § 200.318–200.327 (Uniform Guidance), to: • Maintain written procurement procedures that conform to applicable federal, state, and local laws; • Ensure procurement transactions are conducted in a manner providing full and open competition; • Verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded from participating in federal programs, per 2 CFR § 200.214 and 2 CFR Part 180. Cause The Institute has not formalized its procurement practices in a written policy and staff is not currently required to check suspension and debarment status as part of the vendor selection or contracting process. Effect Without a written procurement policy, the Institute lacks a consistent, auditable standard for procurement decisions, increasing the risk of non-compliance, favoritism, or inconsistent practices across departments. The absence of suspension and debarment checks creates risk that the Institute could enter into agreements with parties who are legally excluded from receiving federal funds, potentially resulting in disallowed costs, reputational harm, or loss of funding. Recommendation The Institute should develop and formally adopt a written procurement policy that addresses methods of procurement, competition requirements, documentation standards, and conflict-of-interest provisions consistent with 2 CFR § 200.318–200.327. The Institute should also implement a documented procedure requiring suspension and debarment verification (via SAM.gov or equivalent) for all vendors, contractors, and subrecipients prior to contract execution, and retain evidence of this check in procurement files. Management Response Management agrees with the finding and recommendation. The Institute is formalizing its procurement practices in a written procurement policy consistent with applicable Uniform Guidance requirements. The policy addresses procurement methods, competition, documentation, conflicts of interest, and suspension and debarment requirements for procurements in accordance with federal regulations. Action Taken The Institute contracted with Visual Compliance to assist with verifying vendors against all available U.S. debarred and suspended lists before entering into covered contracts or agreements with vendors, contractors, or subrecipients. The Institute has developed and approved a Suspension and Debarment policy and staff are required to check suspension and debarment status as part of the vendor selection or contracting process. The Institute is developing a written procurement policy. Evidence of the verification will be retained with the applicable procurement or agreement documentation.

Finding Reference This corrective action plan relates to audit finding 2025 001 as reported in the schedule of findings and questioned costs. Contact Persons Dwayne Shaw, Executive Director, and Michelle Wright, Office Manager , are responsible for implementing and monitoring the corrective actions, maintaining related policies and procedures, and reporting status to those charged with governance. (207) 483-4336 Management’s Response / Concurrence Management agrees with the finding. The organization acknowledges that it does not currently have written policies and procedures addressing certain required Uniform Guidance compliance areas. Planned Corrective Action Management will develop, approve, and implement written policies and procedures designed to comply with applicable Uniform Guidance requirements, including policies over allowable costs/cost principles, cash management, and procurement, including suspension and debarment. Management will also communicate the new policies to relevant personnel and provide training as needed to support consistent implementation. Anticipated Completion Dates Management will finalize and implement the corrective action plan on or before September 30, 2026.

CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact Person Responsible for Corrective Action: Bruce Haggerty, Finance Director Corrective Action: The Houlton Band of Maliseet Indians will take the following actions to address finding 2025- 001: I attended Procurement Training (through Housing and Urban Development) on September 2-3, 2026. HBMI is in the process of updating our Procurement Policy to meet current federal standards. HBMI is also in the process of creating a checklist based on our Procurement Policy to help with assessing the applicable rules during each procurement. Staff will be educated on the new Procurement Policy and Procurement Checklist. Anticipated Completion Date: 9/30/2026

Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.

Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 audit occurred before the corrective measures became effective. Corrective measures implemented include policies and procedures designed to strengthen its procurement and contracting processes. These include: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work Management believes these corrective actions address the deficiencies identified and expects them to be fully effective for construction activities occurring after implementation.

Prior to purchases being made, the Child Nutrition Program Supervisor will check for suspension and debarment of vendors. The accounts payable accountant will also review for suspension and debarment prior to payment being made. Evidence of review will be maintained in an appropriately labeled file each year.

Prior to purchases being made, the Child Nutrition Program Supervisor will check for suspension and debarment of vendors. The accounts payable accountant will also review for suspension and debarment prior to the payment being made. Evidence of review will be maintained in an appropriately labeled file each year. See response to finding 2025-018 above.