Corrective Action Plans

Finding Reference Number: 2025-003 – Internal Control over Compliance in Relation to Procurement Suspension and Debarment Description of Finding: This is a new finding. Upon review of the town’s Bid Ordinance and Charter, a policy could not be found that determines whether a vendor for goods and services was either suspended or debarred from receiving or participating in federal awards, which is required as part of the 2025 Uniform Guidance related to Federal Programs. Additionally, it could not be determined whether any suspension or debarment review had been made and documented. Statement of Concurrence or Nonconcurrence: Concur. Corrective Action: The town will update the Town Bid Ordinance to include the policy that mandates that before any contract or purchase order is awarded using federal funds, staff must verify the vendor’s eligibility status via the federal System for Award Management (SAM.gov). The Town will also update its Policy and Procedures manual to require a printed or digital SAM.gov search certificate to be attached to the procurement file as auditable evidence of the verification. Projected Completion Date: December 31, 2026

Prior to awarding contracts over $25,000, we will conduct a review of the government website (SAM) to confirm contractors have not been suspended or debarred. Documentation will be retained to provide evidence of verification. While we do have a process to select vendors who provide us with the lowest costs, we will update our process to document the rationale on vendor selection on purchases over $2,500. We will update our procurement policy to reflect this process enhancement.

Finding 2025-002 Procurement, Suspension and Debarment Material Weakness in Internal Control Over Compliance and Instance of Material Noncompliance Assistance Listing 21.029 Wabash currently maintains the process of procurement standards and internal controls. While we previously managed contractor selections through established internal practices, we recognize the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash implemented a formal Procurement Policy and Procedure June 30, 2026. This document mandates: • Standardized Selection Criteria: Clear guidelines for the evaluation and selection of contractors to ensure transparency and competition. • Debarment Verification: A required protocol for verifying and documenting that contractors are not excluded or debarred via the System for Award Management (SAM). • Oversight: The Network Operations will be responsible for the implementation and ongoing monitoring of these controls to ensure full regulatory compliance. These measures will ensure that all future procurement activities meet federal requirements and organizational standards for financial integrity. Contact person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer

The EPI Center conducted a comprehensive review of all contractors subject to testing and verified, through alternative procedures, that none were suspended or debarred (e.g., verification through SAM.gov and documented vendor validation processes). As a result, all costs associated with these contracts were determined to be allowable, reasonable, and allocable to the federal award. Accordingly, management concluded that the finding relates to procurement policy implementation, documentation, and compliance processes rather than the allowability, allocability, or eligibility of the expenditures tested.

Management agrees with the finding and will develop and implement written procurement procedures consistent with Uniform Guidance requirements.

Finding 2025-002 – Policies and Procedures Require Review and Update – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Significant Deficiency Corrective Action Plan: Strengthening Board governance, ethical expectations, policy ownership, accountability, and delegated authority. Initial Deliverables • Code of Ethics; • Conflict-of-Interest Policy; • Whistleblower and Reporting Policy; • Delegation of Authority Matrix; • Spending and Approval Authority Matrix; • Signature Authority Matrix; • Policy Development and Review Policy; • Board Governance Framework; • Annual policy acknowledgment process; and • Governance training plan. Standardize the Housing Authority’s major operating processes and reduce reliance on undocumented institutional knowledge. Initial Deliverables • Standard Operating Procedure framework; • Priority SOP inventory; • Housing Choice Voucher processing SOPs; • Public housing occupancy and recertification SOPs; • Waiting-list administration SOPs; • Inspection scheduling and tracking procedures; • Intake and communication procedures; • Position-responsibility matrix; • Updated job descriptions; • Workload assessment; • Staff onboarding procedures; and • Cross-training plan. Improve financial accuracy, safeguarding of assets, segregation of duties, reconciliations, reporting, and management review. Initial Deliverables • Financial Policies and Procedures Manual; • Accounts-payable controls; • Check-run and payment-review procedures; • Payroll approval procedures; • Cash-handling procedures; • Laundry-revenue procedures; • Bank and general-ledger reconciliation procedures; • Monthly and annual financial-review checklist; • Audit-adjustment reconciliation procedures; • Fixed-asset and nonexpendable-equipment inventory procedures; • Capitalization policy update; • Investment policy update; • Creative Housing financial-accounting review; • Inter-entity transaction policy; • Corrective-action plan for questioned costs; • Financial close calendar; • CFO and Executive Director review responsibilities; and • Board financial dashboard. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: • Phase 1: Target Date of completion: November 30, 2026 o Implementation and Communication about the Red Flags Ethics Hotline o Identification and creation of needed policies and structural tools o Updating of current policies as needed • Phase 2: Target Date of Completion: April 30, 2027 o Training on new policies/expectations and accountability standards.

BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.

2025-002 [2023-002]—SF 425 Reporting CORRECTIVE ACTION PLAN Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Federal Agency: United States Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Federal Award Identification Number and Year: 2022-70423-38069, 2021-70030-35719 Award Period: Project period: multiple; Budget period: multiple Questioned Costs: None Statement of Condition NMFMA did not have adequate controls over the SF-425 reporting timeline. For two out of two SF-425 Federal Financial Reports tested, the annual and close-out reports were submitted after the due date (90 days for annual and close-out reports). Also, the annual report seems to have some clerical errors and the amounts reported did not match the general ledger for the period reported, due to markets payments being reconciled late. The difference is immaterial, and client will adjust in the next report. CriteriaIn accordance with 2 CFR 200.327 (Financial Reporting) and award terms requiring SF-425 is required to be submitted for the Food Insecurity Nutrition Incentive Grants program. Recipients use the SF-425 as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status. The due dates are 30 days after the end of the reporting period for quarterly reports, and 90 days after the end of the reporting period for the annual and close-out reports. Also, the reports need to be reviewed for accuracy and completeness. CauseNMFMA has not properly implemented a formal reporting calendar, responsibility matrix, or documented pre-submission tie-out/review due to staff turnover. EffectNoncompliance with reporting requirements; risk of USDA sanctions; risk that SEFA and drawdown monitoring rely on inaccurate data. RecommendationEstablish an SF-425 compliance calendar with automated reminders; assign preparer and independent reviewer roles; perform a documented tie-out (SF-425 to GL, bank, and SEFA) with sign-offs before submission; NMFMA staff should improve internal controls by implementing reminders with the due dates of the reports and reviewing the accuracy of the reports before submission. View of Responsible OfficialThe Executive Director will take action to make sure USDA reports are filed on time. The ED will work with the Finance Director and other accounting staff to ensure deadlines are met. TimelineTarget implementation September 30, 2026. Staff Responsible Executive Director SIGNATURE TITLE DATE

Response and Views of Responsible Officials Management concurs with this finding. Management acknowledges that, during the audit period, the Organization did not maintain federally compliant written procurement procedures that addressed the requirements of Uniform Guidance for procurement transactions charged to federal awards. While the Organization generally followed purchasing and approval practices, those procedures were not formally documented and did not specifically address federal procurement standards, suspension and debarment verification, or procurement documentation requirements. Since the audit period, the Organization has substantially strengthened its procurement policies and internal controls. The Financial Policies Manual has been revised to include formal procurement procedures, purchasing approval requirements, competitive purchasing expectations, documentation standards, and financial oversight responsibilities. In addition, purchasing responsibilities have been incorporated into the Organization's strengthened internal control structure, including review by the internal bookkeeper, Executive Director, Executive Committee, and Board of Directors, as appropriate. Management also notes that strengthening procurement procedures was identified through the MIECHV monitoring process and was incorporated into the Organization's broader financial management improvements. Management believes these actions substantially improve compliance with federal procurement requirements and reduce the risks identified during the audit. Management has completed the following corrective actions: • Revised and expanded the Financial Policies Manual to include federally compliant procurement procedures and purchasing controls. • Established documented approval thresholds and purchasing authority for procurement transactions. • Implemented procurement documentation requirements, including supporting invoices, approval documentation, and retention of procurement records. • Strengthened internal review of procurement transactions through involvement of the internal bookkeeper, Executive Director, Executive Committee, and Board of Directors, as appropriate. • Incorporated procurement procedures into the Organization's broader system of internal financial controls and oversight. Management will complete the following additional actions: • Develop and implement written procedures for suspension and debarment verification for applicable federally funded purchases, including documentation of SAM.gov verification. • Develop a standardized Federal Procurement Checklist to document procurement method, approvals, required competition, suspension and debarment verification, and supporting documentation for federally funded purchases. • Establish standardized procurement files to ensure all required procurement documentation is maintained in accordance with the Organization's record retention policy. • Provide training to employees responsible for initiating, approving, or documenting procurement transactions charged to federal awards. • Conduct an annual review of procurement policies and procedures to ensure continued compliance with Uniform Guidance and federal grant requirements. Responsible Official: Josie Brittain Anticipated Completion Date: September 30, 2026

Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of the Treasury Award Number and Year: 2021 Compliance Requirement: Procurement and Suspension and Debarment Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The program managers lacked a complete understanding of federal grant requirements and overlooked this procedure. To resolve the matter, the City Manager and department leaders convened and suggested that staff receive proper training. They will continue to review the training schedule, factoring in staff availability, venue options, and budget limits. All current non-Federal entities have been verified. Name of Responsible Person: City of Merced’s Leadership and Grant Program Managers Projected Implementation Date: June 30, 2027

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following: --One instance where the Cooperative did complete price comparisons; however, the memo documenting the procurement did not reference the price comparison. The procurement file did not obtain all required components of the procurement process including rationale for selecting the vendor or the procurement method used. --One instance where the Cooperative did not follow the procurement process as detailed in the procurement policy and no documentation was retained to support the rationale for selection of vendor. Corrective Action Plan: The Cooperative has taken steps to remedy the findings of the 2025 single audit: --Management reviewed procurement policies with department heads that are responsible for contractor and material procurement for grants. --Accounting staff will now review all grant expenditures at least monthly to catch new vendors in a more timely manner and assure that appropriate procurement policy has been adhered to prior to contractor starts work or material is used on projects. Responsible Individuals: Jeremy Richert, Chief Executive Officer and Kelly Gibbs, Chief Financial Officer Anticipated Completion Date: July 2026

Finding 2025-003 Federal Agency Name: United States Department of Health and Human Services Program Name: Congressional Directives FFAL #93.493 Finding Summary: Testing of the federal program identified the following: 􀁸 The Hospital’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. 􀁸 Instances where the Hospital did not follow the procurement process, and/or retain documentation for reasoning of selection of vendor. Corrective Action Plan: For Finding 2025-003, the Hospital has updated and approved its Federal Procurement Policy and Procedure to incorporate all required elements of Uniform Guidance and strengthen compliance with federal grant requirements. In addition, the Hospital revised its Capital Request process to include formal procurement requirements, vendor selection documentation, and approval workflows. Effective immediately, no federal funds will be expended until the procurement process has been fully completed and documented in accordance with the revised policy. Management has implemented controls to ensure procurement records are maintained, including documentation supporting vendor selection and purchasing decisions. To support compliance and consistent application of the new requirements, education and training on the revised procurement and capital request processes will be provided to all managers on August 5, 2026. Hospital leadership will monitor adherence to these procedures through ongoing review and oversight to ensure compliance with federal regulations and prevent future occurrences of this finding. Responsible Individuals: Wesley Babers, Chief Executive Officer and Ashley Jaramillo, Chief Financial Officer Anticipated Completion Date: August 2026

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE

The Partnership will develop and implement comprehensive written subrecipient monitoring and procurement policies aligned with Uniform Guidance. Procedures will include verification of suspension and debarment status (e.g., SAM.gov), incorporation of required compliance terms in subaward agreements, tracking of subrecipient funding by program, implementation of a risk-based monitoring framework, and documentation of monitoring activities including financial and programmatic reviews. Staff will be trained on these updated procedures, and compliance reviews will be centralized within the finance and administrative function.

FINDING 2025-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas Dippel, CPA Contact Phone Number and Email Address: (812) 683-2211 / ct@huntingburg-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with the City’s attorney to revise its current policy to include federal regulations and procedures related to Procurement and Suspension and Debarment. Once revised, the City will follow its policy to ensure compliance with the compliance requirement. Anticipated Completion Date: September 30, 2026

FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that price reasonableness analyses are performed and documented prior to entering into agreements with vendors in accordance with Uniform Guidance procurement requirements. The University will implement the following corrective actions: • Continue to monitor and review procurement policies and procedures for changes in applicable federal requirements and institutional practices. Procurement policies, procedures, and related documentation tools will be updated as necessary, and the standardized procurement checklist will be periodically reviewed and revised to ensure alignment with current procurement policies and Uniform Guidance standards. • Require supervisory review of procurement transactions to ensure all required procurement documentation, including price reasonableness determinations, is completed and retained prior to final approval of vendor agreements. • Provide training to procurement and departmental personnel involved in federally funded procurements regarding Uniform Guidance requirements and documentation standards. • Conduct periodic monitoring of procurement files to verify ongoing compliance with procurement policies, procedures, checklist requirements, and applicable federal regulations. These corrective actions will strengthen the University's internal controls over procurement activities and help ensure compliance with Uniform Guidance requirements related to procurement documentation and vendor selection. Individual(s) Responsible for Corrective Action Plan: Randi Vandegrift, Strategic Sourcing Manager John Skjeveland, Controller Estimated Completion Date: September 30, 2026

The Corporation’s legal counsel is currently working to draft amendments to those contracts discovered during the audit process that did not contain specific Uniform Guidance (2 CFR § 200.327 and 2 CFR Part 200, Appendix II) provisions referenced in the finding narrative. The Corporation expects these amendments to be finalized and executed by the end of March 2026. Anticipated Completion Date: March 31, 2026 Contact Person: Justin Medeiros, Senior Controller / CFO, Rhode Island Commerce Corporation justin.medeiros@commerceri.com

The Shaquille O'Neal Foundation acknowledges the observation regarding the documentation requirements under 2 CFR §200.318(a). While the Foundation did not have a formal written procurement policy in place during the audit period, it did implement procurement practices designed to comply with the Uniform Guidance requirements. Specifically, the Foundation maintained oversight of contractor performance in accordance with 2 CFR §200.318(b) by ensuring that all contractor agreements and applicable purchase orders incorporated the required federal contract provisions and procurement language. The Foundation monitored contractor performance to verify that work was completed in accordance with the terms, conditions, and specifications of each agreement. The Foundation recognizes that documenting these procurement procedures in a formal written policy is a separate requirement under 2 CFR §200.318(a). To address this deficiency, management has developed and adopted a written Procurement Policy that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). The policy formalizes the Foundation's procurement procedures, internal controls, competition requirements, contract oversight responsibilities, and documentation standards to ensure ongoing compliance with federal regulations. Management believes this corrective action fully addresses the audit finding and strengthens the Foundation's procurement governance for future federal awards.

2025-005: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edward Dickie, Business Manager.

2025-004: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Jim Serbin, CFO.

Contact Persons – Greg Welch, Finance Director& Jarek Wigness, City Engineer Corrective Action Plan – City officials have already implemented internal controls to ensure the proper oversight of federal programs according to the Uniform Grant Guidance Policy for Federal Revenue Sources. Completion Date – Ongoing

2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Responsible Party: Emma McQuillan, Chief Financial Officer Completion Date: 12/5/2024

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

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.