Corrective Action Plans

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.

Condition During our testing, we noted that the Educational Foundation's written procurement policy did not incorporate all applicable Uniform Guidance procurement requirements. Specifically, the policy did not adequately address procurement methods and dollar thresholds, suspension and debarment verification, and required contract provisions. As a result, the Association's written policy was not fully consistent with the requirements of 2 CFR Part 200 Corrective Action Plan Corrective Action Planned: Management acknowledges the auditor's recommendation regarding the enhancement of the Association's procurement policies to ensure full compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §§ 200.317–200.327). LeadingAge Michigan has initiated a comprehensive review of its existing procurement policies and procedures to ensure they fully incorporate all applicable federal procurement requirements. The revised policy will include provisions addressing procurement methods based on established dollar thresholds, competition requirements, documentation and record retention standards, contractor responsibility determinations, suspension and debarment verification, conflict of interest requirements, and all required federal contract provisions applicable to federally funded awards. Management will also establish standardized procurement documentation and review procedures to promote consistent application of the policy and to ensure compliance is adequately documented for all applicable purchases funded through federal awards. In addition, personnel responsible for procurement and grant administration will receive training on the updated procurement policy and the requirements of 2 CFR Part 200. This training will emphasize proper procurement planning, documentation, competitive purchasing requirements, and compliance with federal regulations to ensure consistent implementation throughout the organization. Management is committed to maintaining strong internal controls over federal awards and will periodically review procurement practices to ensure ongoing compliance with Uniform Guidance requirements. Name(s) of Contact Person(s) Responsible for Corrective Action: David Herbel, President and CEO Dalton Herbel, Vice President of Public Policy Kelly Price, Member Success Coordinator Anticipated Completion Date: 9/30/2026

2024-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

Finding Number 2024-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The Office of Management and Enterprise Services (OMES), Central Purchasing Division, respectfully submits this response regarding the use of federal funds in connection with statewide contracts established through the Rolling Request for Proposal (RFP) pilot program. Since the audit period, OMES has implemented significant enhancements to its statewide contracting processes to further strengthen documentation, oversight, and compliance with both state procurement law and Uniform Guidance. These enhancements also address the recommendations identified in this finding. Compliance with Uniform Guidance (2 CFR Part 200) OMES affirms that procurements conducted under the Rolling RFP pilot program were performed in accordance with applicable provisions of Uniform Guidance and the Oklahoma Central Purchasing Act, including but not limited to 2 CFR §§ 200.317, 200.318, and 200.404. Pursuant to 2 CFR §200.317, OMES follows the same procurement policies and procedures for federal funds as are used for non-federal funds. The Rolling RFP model did not eliminate competitive procurement. Rather, it modified the timing of vendor qualification by allowing qualified vendors to compete for inclusion on the statewide contract throughout the open solicitation period while agencies continued to conduct project specific Statements of Work under those contracts. Consistent with 2 CFR §200.318(a), OMES maintains oversight to ensure that procurements are conducted in a manner providing full and open competition, and that contractors perform in accordance with the terms, conditions, and specifications of their contracts. The Rolling RFP model increased vendor participation and competition by allowing qualified suppliers to submit responses on a continuous basis, thereby expanding the competitive pool available to agencies. Further, in accordance with 2 CFR §200.404, OMES ensures that costs are reasonable by requiring evaluation of pricing at both the contract award level and the transaction level. Vendors are vetted through a formal evaluation process, and Statements of Work (SOWs) are developed with agency and subject matter expert involvement to confirm that pricing reflects what a prudent person would incur under similar circumstances. Vendor pricing remained subject to procurement review, agency evaluation, statement-of-work negotiations, market comparisons, procurement approval processes, and applicable fair and reasonable price determinations required under state procurement law and Uniform Guidance. Additionally, OMES Central Purchasing operates under formalized internal procedures, including its Framework Agreement Creation Standard Operating Procedure, which explicitly requires adherence to Uniform Guidance. The SOP mandates vendor vetting, competitive evaluation, including the contract clauses required by 2 CFR §200.327 and Appendix II to Part 200, and documented evaluation methodologies to ensure transparency, consistency, and compliance in all framework (statewide) agreements. In addition, OMES has adopted the first-ever Oklahoma Procurement Manual, which establishes standardized statewide guidance for procurement planning, contract administration, federal grant compliance, documentation standards, and competition requirements. The manual reinforces Uniform Guidance requirements and provides agencies with consistent statewide procurement procedures for acquisitions involving both state and federal funds. Program Structure and Administrative Considerations The Rolling RFP pilot program functioned as a framework agreement structure, wherein suppliers were pre-qualified through a competitive solicitation process and agencies subsequently issued project-specific Statements of Work. This approach was designed to align with allowable procurement methods under Uniform Guidance. OMES recognizes, however, that the continuous open nature of the solicitation created administrative challenges and increased complexity in maintaining consistent documentation and oversight as vendor participation scaled. Documentation and Administrative Enhancements Although the pilot program did not have a standalone written procedure specific to Rolling RFPs during the audit period, it operated under existing procurement statutes, standardized solicitation procedures, evaluation documentation, internal operating procedures, and statewide contract templates. Documentation practices have since been further standardized and consolidated. While the program operated under existing procurement statutes, solicitation procedures, evaluation documentation, and internal operating practices, OMES has since implemented additional written procedures, standardized documentation requirements, and centralized guidance to improve consistency, transparency, and ease of audit review. These enhancements strengthen an already competitive procurement process by providing more comprehensive documentation of procurement decisions and contract administration. Program Closeout Following a comprehensive review, the State Purchasing Director formally determined that the Rolling RFP pilot program would be closed effective July 1, 2024. All resulting contracts have transitioned to standard statewide contract structures, which incorporate defined solicitation periods and controlled opportunities for vendor participation through supplemental solicitations. Because the pilot program has been discontinued and replaced with traditional statewide contracting methods, legislative recommendations regarding continuation of the pilot are no longer necessary. Remedial Actions Aligned to Uniform Guidance In response to audit observations and in furtherance of compliance with Uniform Guidance, OMES is implementing the following corrective actions: 1. Enhanced Competition at the Transaction Level (2 CFR §200.319) For all service-based procurements utilizing statewide contracts, agencies will be required to conduct a documented second level of competition (e.g., multiple quotes, mini-bids, or competitive SOW processes) to ensure full and open competition at the task/order level. 2. Structured Re-Competition of Vendor Pools OMES will replace continuously open solicitations with time-bound supplemental RFPs, ensuring periodic recompetition and maintaining a manageable and auditable procurement environment. 3. Strengthened Cost Analysis and Documentation (2 CFR §200.324) OMES will reinforce requirements for price analysis and cost reasonableness determinations at both the contract and transaction levels, with enhanced documentation standards to support audit review. 4. Formalized Policies and Procedures (2 CFR §200.318(a)) OMES Central Purchasing is dedicated to documenting all procurement processes, particularly those impacting purchases using federal funds. This includes comprehensive SOPs, required contract attachments (including federal terms), and standardized evaluation and recordkeeping practices. Specifically, we have created SOPs for pilot programs and for statewide contracts generally. While comprehensive written procedures specific to the Rolling RFP pilot program had not yet been consolidated into a standalone procedure during the audit period, the program operated under existing procurement statutes, statewide solicitation procedures, evaluation documentation, internal operating procedures, and standardized contract documents. OMES has also implemented standardized procurement templates and required federal contract attachments that incorporate the clauses required under 2 CFR §200.327 and Appendix II to Part 200. These standardized documents promote consistent compliance across procurements utilizing federal funds. 5. Statewide Procurement Manual OMES has recently released the first-ever Oklahoma Procurement Manual, which provides statewide guidance to agencies and includes a dedicated section on federal grant compliance. The manual reinforces Uniform Guidance requirements, including competition, cost reasonableness, and documentation standards. 6. Ongoing Oversight and Training OMES will continue to provide training, procurement memoranda, and guidance to agencies to ensure consistent understanding and application of federal requirements, while reinforcing that subrecipients are responsible for compliance with the specific terms of their federal awards. Anticipated Completion Date Sine Die Responsible Contact Person Amanda Otis, State Purchasing Director for the State of Oklahoma

FINDING 2024-005 Finding Subject: Child Nutrition Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Formal procurement procedures have been established including micro-purchase and small purchase thresholds. Required price quotes are obtained and documented. Procurement history is maintained, including rationale and vendor selection. Vendor suspension and debarment checks are performed using SAM.gov or certifications. OPAA provides oversight of procurement processes and monitoring is ongoing. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance procurement control activities, and provide ongoing monitoring to ensure compliance with federal procurement standards, suspension and debarment requirements, and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

Root Cause Analysis: During the initial startup phase of federal program implementation, The EPI Center utilized existing partner and vendor contract templates to support rapid program launch and continuity of services. At that time, procurement processes had not yet been fully centralized, and standard federal contract provisions required under 2 CFR Part 200, Appendix II were not consistently incorporated across all agreements. This condition reflects a timing and process alignment issue during organizational scaling, rather than a lack of procurement oversight or intent to circumvent federal requirements. Response, with details: ☒Corrective Action Plan ☐Clarification 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. Importantly, the auditor confirmed that there were no questioned costs associated with this finding. Accordingly, this matter reflects a documentation and process alignment issue related to federal contract provisions rather than a deficiency affecting the allowability or eligibility of expenditures. Corrective Actions The EPI Center has taken immediate and proactive steps to strengthen procurement compliance and ensure full alignment with federal requirements: 1. Federal Contract Addendum (Implemented – April 2026) A standardized addendum incorporating all required provisions under 2 CFR Part 200, Appendix II has been developed and will be required for all applicable contracts upon Board approval. 2. SAM.gov Verification Embedded (Completed – February 2026) A formal suspension and debarment verification step has been incorporated into the procurement checklist, with documentation retained for audit purposes. Verification will be completed and retained in the procurement file prior to contract execution. 3. Centralized Contract Approval Workflow (Implementation Initiated) A revised procurement and contract approval process has been implemented to ensure all agreements undergo centralized review for federal compliance prior to execution. The revised process will be submitted to the Board for approval April 23, 2026. 45 4. Procurement Process Standardization (Implementation Initiated) Templates and procedures have been updated to ensure consistent inclusion of required federal clauses across all applicable vendor agreements. Management revised its processes upon becoming aware of these matters and created systems to ensure compliance going forward. The revised procurement protocol will be submitted to the Board for approval April 23, 2026. Management emphasizes the following validated conclusions: ● Auditor confirmed $0 questioned costs ● All vendors were verified as eligible and not debarred ● All expenditures were allowable, reasonable, and properly supported Accordingly, this finding represents a documentation and process standardization matter rather than a deficiency in allowability, eligibility, or financial integrity. Responsible Party: Project Lead, Finance Specialist, Finance and Compliance Manager Timeline for Completion: April 2026

The City staff will be stricter in following its established internal control procedures to ensure that all reporting requirements are met and submitted timely. The City will also establish access to the Integrated Disbursement and Information System (IDIS) for another member of the Finance Department in a backup capacity. Where applicable, the City will request an extension from the funding agency and maintain a record of the approval when a report cannot be submitted by the due date.

The Government will retain all necessary supporting documentation for purchase orders, contracts, and vendor profiles to ensure adherence to internal policies and regulatory requirements. Management will implement procedures to regularly review and verify that all procurement activities are properly documented and compliant with applicable regulations. Management will implement a formal process to ensure all executed contracts are timely included on GVIBUY. DPP will liaise more frequently with DOF IT team to rectify any potential system issues that can affect data accuracy. In collaboration with DPP and DOF, OMB will do the following: Formalize Policies and Procedures (SOP Updates): OMB will update its internal Standard Operating Procedures (SOPs) to clearly define: • Roles and responsibilities for procurement oversight • Required documentation standards - to ensure all procurement actions related to federal awards are captured, documented, and readily accessible for audit purposes. • Review and approval workflows Training and Capacity Building: OMB will conduct training sessions for all staff involved in procurement and grant management to reinforce compliance with: • Uniform Guidance (2 CFR 200.318–200.327) • Local procurement requirements (Title 31 VIC)

2024-011– EDUCATION STABILIZATION FUND - REPORTING – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain documentation for the data that was submitted to the North Dakota Department of Public Instruction (NDDPI) for the state’s completion of the Annual Report for the Education Stabilization Fund program. We were able to obtain the information that was submitted from NDDPI; however, due to issues identified with the accuracy of underlying accounting records we were unable to determine if the information included in the report is accurate. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) for the CTE Center. Therefore, we were unable to determine if the CMAR selection was properly completed. In addition, Willison Basin Public School did not have a procurement policy. Management’s Response: We agree. The District will work to ensure that future projects are properly procured within state law and federal guidelines. Anticipated Completion Date: FY 2025

Develop procurement policy for federal grants noting that bids on federal grants will be advertised for at least three weeks.

Finding 2024-007: Procurement and Suspension/Debarment Documentation and Record Retention – Material Weakness Condition: NACA has written procurement policies that comply with Uniform Guidance; however, documentation evidencing compliance with procurement procedures and suspension and debarment requirements was not consistently retained. Corrective Action: Management will enhance implementation of existing procurement policies by ensuring that documentation supporting procurement decisions and suspension and debarment checks (e.g., SAM.gov verification) is consistently retained for applicable transactions. Procedures will be reinforced to ensure appropriate documentation is maintained for audit and monitoring purposes. Name of Person Responsible: Walter McCullough, CFO Anticipated Date of Completion: May 31, 2026

Views of responsible officials and planned corrective actions - Management concurs with the audit findings and plans to review and implement additional internal policies and procedures related to procurement and suspension and debarment protocols for grant funding in future periods.

Management's Response: AMHE has Established for the Aha Macav Housing Entity by Board action on December 28th, 2017. The effective date of this Statement is December 28th, 2017. This Statement of Procurement Policy complies with the Native American Housing Assistance and Self Determination Act of 1996, as amended, and the implementing regulations at 24 CFR 1000, 24 CFR 1003, and the procurement standards of 2 CFR 200. AMHE will adhere to the Procurement Policy hat has been established and clarify the process so that no steps are skipped in the process moving forward. Estimated Completion Date: Immediately AMHE will adhere to the Procurement Policy currently in place. This will be addressed with AMHE staff prior to 6/30/26. Responsible Party: Maintenance Supervisor, Comptroller and Interim Director.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Passed Through Payments from the State of New Hampshire Department of Environmental Services Corrective Action Plan: The District will draft a procurement policy which conforms to the requirements set forth in the Uniform Guidance, specifically addressing the requirements of 2 CFR § 200.318 through 200.327. Individual Responsible: Roland Seymour, Commissioner Arthur Demass, Commissioner Steve Partridge, Commissioner Anticipated Implementation Date of Corrective Action: May 2026.

Finding 2024-002 Procurement, Suspension and Debarment Material Weakness in Internal Control Over Compliance and Instance of Material Noncompliance Assistance Listing 21.029 Wabash is currently in the process of formalizing its 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 will implement a formal Procurement Policy and Procedure by June 30, 2026. This document will mandate: • 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 City will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Management acknowledges the finding and agrees that strengthening procurement controls is necessary to ensure full compliance with federal requirements. To address this issue, the Parish has implemented a standardized contract for use in federally funded procurements that incorporates all applicable requirements under 2 CFR §200.327 and Appendix II to Part 200. In this specific instance the two contracts noted were state contracts. When state contracts are utilized, the Parish will take the necessary steps to validate that such contracts include all required federal contract provisions prior to utilizing any state contracts. Guidance will also be provided to all procurement personnel involved in contracting to reinforce understanding and consistent application of federal requirements. Management expects these corrective actions to be implemented in the near term and will conduct ongoing monitoring to ensure compliance and effectiveness of the enhanced controls. Interim Finance Director Victor LaRocca, Purchasing Director Renny Simno and Assistant Accounting Director Charles “Joey” Vasquez will ensure that this is enacted immediately and that guidance is provided to procurement personnel by June of 2026.

CORRECTIVE ACTION PLAN The Town of Billerica, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17th Floor Boston, MA 02109 Audit Period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding 2024-003: Missing Federally Required Procurement Clauses in Vendor Contracts Views of Responsible Officials: The Town is committed to strengthening its procurement practices and ensuring compliance with Uniform Guidance requirements. To address this issue, the Town will develop and implement standardized contract templates, and a comprehensive checklist of required federal clauses applicable to federally funded procurements for any future federal dollars. The Town will formalize procedures to ensure that a secondary review is consistently performed and documented for all required federal reports prior to submission and will designate a member of management or another qualified official to perform and document this review. Official Responsible for Implementing Corrective Action: Amit Chhayani Town Accountant

2024-004 Improve Internal Controls Over Procurement Federal Agency: Department of the Treasury Award Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: 2024 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria: Per 2 CFR 200.318–200.327, non-federal entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards set forth in the Uniform Guidance. For purchases exceeding the micro-purchase threshold, procurement must include documented procedures, full and open competition (unless an exemption applies), and executed contracts. All contracts must be fully executed and amendments provided for any changes to terms or scope. Additionally, any exemption from competitive bidding must be documented, and only applies to the period and scope approved. Suspension and debarment checks must also be performed and documented for covered transactions with vendors. Condition: During our testing of one procurement transaction under the SLFRF program, the Town received an exemption from bidding requirements typically required under Massachusetts’ state law. The exemption was due to an initial emergency procurement; however, expenditures continued to be incurred after the initial emergency ended and the associated contract’s substantial completion date. The Town did not provide contract amendments to extend the contract, nor did it perform additional procurement procedures for expenditures that occurred after the emergency period ended and outside the scope of the exemption. In addition, the contract with the vendor was not countersigned by the Town and therefore a fully executed contract did not exist. Further, suspension and debarment checks for vendors were not retained as required. Cause: The Town did not ensure contracts were fully executed prior to commencement of work, did not maintain documentation or perform procurement for additional expenditures incurred after the completion date of the original contract and outside the scope of the emergency exemption, and did not maintain documentation of required suspension and debarment checks. Effect: Failure to obtain a fully executed contract, perform and document suspension and debarment checks, and appropriately document or procure additional services beyond the contract term increases the risk of noncompliance with federal procurement requirements and may expose the Town to possible unallowable costs, conflicts of interest, or ineligible vendor participation. Recommendation: The Town should implement policies and procedures to ensure all contracts are fully executed prior to work commencement, and any extensions or additional services beyond the original contract are properly documented via contract amendments or appropriate procurement methods in accordance with Uniform Guidance. The Town should also ensure continued monitoring and documentation of procurement exemptions and maintain documentation of all suspension and debarment checks for vendors paid with federal funds. Views of Responsible Official: The Town implemented a purchasing policy to ensure compliance with federal awards required under the uniform guidance. The adopted policy addresses the concerns identified in 2024-004.

AEA agrees with the finding. Management acknowledges that, while the organization followed procurement guidance contained in the Weather Assistance Program Policies and Procedures Manual, it did not formally adopt an organization-wide written procurement and suspension and debarment policy fully compliant with 2 CFR Part 200.317–200.327. AEA will formally adopt a written procurement policy that incorporates all applicable Uniform Guidance requirements, including procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and procedures for suspension and debarment verification for covered transactions. Management will also implement related procedures and control documentation to support consistent application of the policy across federally funded programs. AEA will provide training to relevant personnel and will maintain documentation evidencing procurement review and suspension/debarment verification, where applicable. Management believes these corrective actions will bring the organization into compliance and reduce the risk of future noncompliance.

Audit Finding Reference: 2024-003 Improve Internal Controls Over Procurement Planned Corrective Action: The Town will review and revise its procurement procedures to ensure that federal requirements under the Uniform Guidance are followed for all federally funded transactions. For future federally funded contracts, the Town will maintain documentation demonstrating adherence to Uniform Guidance procurement requirements, including appropriate justifications for exemptions. The Town will ensure program staff are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: February 2, 2026

Audit Finding Reference: 2024-005 Improve Procurement Procedures Planned Corrective Action: The Town will revise its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town will ensure adequate documentation is retained for all federally funded procurements, and that procurement staff and grant managers are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: Management has made staff aware of the Federal procurement requirements associated with Federal grants and will work with grant managers, finance and procurement department staff to ensure this requirement is implemented in fiscal year 2026; on or about March 18, 2026.

The Municipality of Comerío made a contract with an auditing firm to work on the reports and submission of the FASS-PH financial report compliance for the years in which the reports were not submitted. Furthermore, instructions were given for the HUD Coordinator to monitor the delivery of reports by the contracted auditing firm and to ensure that the contract for this service is finalized.